Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
The High Court allowed the petition and permitted the petitioner to obtain Form 10IC for the Assessment Year 2021 and make a fresh application. The court relied on Wipro Limited [2022 (7) TMI 560 - Supreme Court] and held that the respondent was required to consider the facts of the case by permitting the petitioner to file a fresh Form 10IC and condoning the delay in filing such Form u/s 119(2)(b) of the Act. The provisions of Section 119(2)(b) are meant for redressal of grievances and hardships caused to the petitioner. The petitioner had adopted the option for taxation u/s 115BAA of the Act, which grants relief to companies by enabling them to pay a reduced tax rate of 22% subject to certain conditions.
The High Court allowed the petition and permitted the petitioner to obtain Form 10IC for the Assessment Year 2021 and make a fresh application. The court relied on Wipro Limited [2022 (7) TMI 560 - Supreme Court] and held that the respondent was required to consider the facts of the case by permitting the petitioner to file a fresh Form 10IC and condoning the delay in filing such Form u/s 119(2)(b) of the Act. The provisions of Section 119(2)(b) are meant for redressal of grievances and hardships caused to the petitioner. The petitioner had adopted the option for taxation u/s 115BAA of the Act, which grants relief to companies by enabling them to pay a reduced tax rate of 22% subject to certain conditions.
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