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 exemption u/s 11 for assessment of a trust due to rejection of application for condonation of delay in filing Form 10B. The petitioner inadvertently delayed filing Form 10B due to the clerical staff of the Chartered Accountant suffering from a brain tumor. The High Court held that although the audit report was obtained on 07.05.2015, prior to the return filing date of 26.09.2015, the respondent adopted a pedantic approach in rejecting the condonation application. The reasons provided by the petitioner cannot be discarded as not constituting genuine hardship. The High Court quashed the impugned order, directing the respondent to condone the delay in filing Form 10B to enable the petitioner to obtain exemption u/s 11.
Denial of exemption u/s 11 for assessment of a trust due to rejection of application for condonation of delay in filing Form 10B. The petitioner inadvertently delayed filing Form 10B due to the clerical staff of the Chartered Accountant suffering from a brain tumor. The High Court held that although the audit report was obtained on 07.05.2015, prior to the return filing date of 26.09.2015, the respondent adopted a pedantic approach in rejecting the condonation application. The reasons provided by the petitioner cannot be discarded as not constituting genuine hardship. The High Court quashed the impugned order, directing the respondent to condone the delay in filing Form 10B to enable the petitioner to obtain exemption u/s 11.
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