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 HC allowed the assessee to file Form 10IC before the AO to claim benefit u/s 115BAA. Despite not filing Form 10IC along with the return, the assessee's conduct showed intention to opt for taxation u/s 115BAA. The HC considered the inadvertent procedural error due to Covid-19 pandemic and difficulties in uploading the form. The AO was directed to permit filing Form 10IC and consider granting relief if other conditions are met.
The HC allowed the assessee to file Form 10IC before the AO to claim benefit u/s 115BAA. Despite not filing Form 10IC along with the return, the assessee's conduct showed intention to opt for taxation u/s 115BAA. The HC considered the inadvertent procedural error due to Covid-19 pandemic and difficulties in uploading the form. The AO was directed to permit filing Form 10IC and consider granting relief if other conditions are met.
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