Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
Nature-dependent electricity contracts receive new Ind AS accounting, hedge designation, transition and financial-statement disclosure requirements fr...
Alternative GST remedy permitted protective writ intervention for ex parte adjudication, preserving independent appellate review of input tax credit d...
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The High Court upheld the Tribunal's decision to condone the delay in filing Form 10B by the assessee, rejecting the Revenue's reliance on the Supreme Court's ruling in M/s Wipro Limited. The Court distinguished the present case from Wipro, where the declaration u/s 10B(8) was filed belatedly with the revised return. Here, the assessee had electronically filed Form 10B during the appellate proceedings, and the delay was rightly condoned by the CIT(A) and Tribunal. The Court endorsed an equitable, balanced, and judicious approach in such cases, following its earlier decisions in Sarvodaya Charitable Trust and Social Security Scheme of GICEA. The Revenue's appeal was dismissed as no substantial question of law arose.
The High Court upheld the Tribunal's decision to condone the delay in filing Form 10B by the assessee, rejecting the Revenue's reliance on the Supreme Court's ruling in M/s Wipro Limited. The Court distinguished the present case from Wipro, where the declaration u/s 10B(8) was filed belatedly with the revised return. Here, the assessee had electronically filed Form 10B during the appellate proceedings, and the delay was rightly condoned by the CIT(A) and Tribunal. The Court endorsed an equitable, balanced, and judicious approach in such cases, following its earlier decisions in Sarvodaya Charitable Trust and Social Security Scheme of GICEA. The Revenue's appeal was dismissed as no substantial question of law arose.
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