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 court rejected the petitioner's application for condonation of a 216-day delay in filing their Income Tax Returns (ITRs). The reasons cited by the petitioner, delay in receiving the audit report and the COVID-19 outbreak, were not accepted. The audit report was issued on 02.07.2019, and the statements were made available then, so the delay in receiving the report was not a valid reason. The COVID-19 outbreak occurred in March 2020, seven months after the audit report, so it could not justify the delay. The court held that condoning such a delay without genuine hardship would encourage misdeeds and cannot be allowed, especially in revenue matters. The respondent rightly rejected the application as the petitioner failed to justify the delay.
The court rejected the petitioner's application for condonation of a 216-day delay in filing their Income Tax Returns (ITRs). The reasons cited by the petitioner, delay in receiving the audit report and the COVID-19 outbreak, were not accepted. The audit report was issued on 02.07.2019, and the statements were made available then, so the delay in receiving the report was not a valid reason. The COVID-19 outbreak occurred in March 2020, seven months after the audit report, so it could not justify the delay. The court held that condoning such a delay without genuine hardship would encourage misdeeds and cannot be allowed, especially in revenue matters. The respondent rightly rejected the application as the petitioner failed to justify the delay.
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