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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Once a company validly opts for the concessional tax rate u/s 115BAA for an assessment year, it is not required to exercise the option again for subsequent years, unless the initial option is rendered invalid due to violation of conditions specified in Section 115BAB(2). The Appellate Tribunal held that if the Revenue authorities allowed the lower tax rate u/s 115BAA for an assessment year without finding any error, the company need not file Form 10-IC or exercise the option afresh for subsequent years u/s 115BAA(5). The assessee's appeal was allowed, as the company had validly claimed the concessional rate for the first time in the previous year, and there was no requirement to make a fresh claim by filing Form 10-IC for the current year.
Once a company validly opts for the concessional tax rate u/s 115BAA for an assessment year, it is not required to exercise the option again for subsequent years, unless the initial option is rendered invalid due to violation of conditions specified in Section 115BAB(2). The Appellate Tribunal held that if the Revenue authorities allowed the lower tax rate u/s 115BAA for an assessment year without finding any error, the company need not file Form 10-IC or exercise the option afresh for subsequent years u/s 115BAA(5). The assessee's appeal was allowed, as the company had validly claimed the concessional rate for the first time in the previous year, and there was no requirement to make a fresh claim by filing Form 10-IC for the current year.
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