Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Denial of benefit of lower 22% tax rate u/s 115BAA due to delay in filing Form 10-IC by petitioner. Petitioner filed return of income in ITR-6 form, exercising option for lower rate by computing tax accordingly. HC held that delay in filing Form 10-IC should have been condoned by authorities instead of rejecting on technical grounds, as petitioner substantially exercised option for lower rate evident from return. Impugned order and intimation quashed, matter remanded to re-process return applying Section 115BAA and allow lower 22% rate, exercise to be completed within 12 weeks.
Denial of benefit of lower 22% tax rate u/s 115BAA due to delay in filing Form 10-IC by petitioner. Petitioner filed return of income in ITR-6 form, exercising option for lower rate by computing tax accordingly. HC held that delay in filing Form 10-IC should have been condoned by authorities instead of rejecting on technical grounds, as petitioner substantially exercised option for lower rate evident from return. Impugned order and intimation quashed, matter remanded to re-process return applying Section 115BAA and allow lower 22% rate, exercise to be completed within 12 weeks.
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