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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ITAT allowed the assessee's appeal regarding denial of exemption under section 11 of Income Tax Act. While the return was not filed within time prescribed under section 139(1), it was filed before the extended deadline under section 139(4A). Following binding CBDT Circular No.173/193/2019, which directs rectification of section 143(1)(a) orders and related demands in such cases, ITAT set aside CIT(A)'s order. Matter remanded to CIT(A) for passing rectification order as per CBDT guidelines. The ruling establishes that belated returns filed within section 139(4A) timeline qualify for exemption, provided other conditions are met.
ITAT allowed the assessee's appeal regarding denial of exemption under section 11 of Income Tax Act. While the return was not filed within time prescribed under section 139(1), it was filed before the extended deadline under section 139(4A). Following binding CBDT Circular No.173/193/2019, which directs rectification of section 143(1)(a) orders and related demands in such cases, ITAT set aside CIT(A)'s order. Matter remanded to CIT(A) for passing rectification order as per CBDT guidelines. The ruling establishes that belated returns filed within section 139(4A) timeline qualify for exemption, provided other conditions are met.
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