Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
The High Court held that the authority erred in rejecting the petitioner's application for condonation of one day's delay in filing the return of income u/s 119(2)(b) of the Act. The reasoning that the return had already been processed u/s 143(1) with a demand raised was flawed and showed non-application of mind. The delay of one day was bona fide due to technical issues and should have been condoned following the principles laid down in the case of Jyotsna Mehta. The Court opined that the paramount jurisprudential principles mandate condonation of such a short delay caused by genuine reasons.
The High Court held that the authority erred in rejecting the petitioner's application for condonation of one day's delay in filing the return of income u/s 119(2)(b) of the Act. The reasoning that the return had already been processed u/s 143(1) with a demand raised was flawed and showed non-application of mind. The delay of one day was bona fide due to technical issues and should have been condoned following the principles laid down in the case of Jyotsna Mehta. The Court opined that the paramount jurisprudential principles mandate condonation of such a short delay caused by genuine reasons.
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