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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The High Court held that the delay of 80 days in filing the Return of Income should be condoned as the petitioner faced genuine hardship due to valid reasons arising from the COVID-19 pandemic. The petitioner, a doctor on COVID-19 duty, lost her father to COVID-19, and her family members were also affected. The valuation of land for computing capital gains could not be completed timely as the valuer, a senior citizen, could not conduct physical verification until mid-February 2021 due to the pandemic situation. The court observed that technicalities should not override genuine human problems preventing timely compliance. The reasons provided by the tax authority for rejecting the condonation plea, such as the petitioner being an educated person with access to tax practitioners, were found unacceptable. Consequently, the High Court quashed the tax authority's order and condoned the 80-day delay in filing the Return of Income for the relevant assessment year.
The High Court held that the delay of 80 days in filing the Return of Income should be condoned as the petitioner faced genuine hardship due to valid reasons arising from the COVID-19 pandemic. The petitioner, a doctor on COVID-19 duty, lost her father to COVID-19, and her family members were also affected. The valuation of land for computing capital gains could not be completed timely as the valuer, a senior citizen, could not conduct physical verification until mid-February 2021 due to the pandemic situation. The court observed that technicalities should not override genuine human problems preventing timely compliance. The reasons provided by the tax authority for rejecting the condonation plea, such as the petitioner being an educated person with access to tax practitioners, were found unacceptable. Consequently, the High Court quashed the tax authority's order and condoned the 80-day delay in filing the Return of Income for the relevant assessment year.
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