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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HC ruled against petitioner companies seeking refund of additional fees charged for delayed financial statement filing. Companies held AGM on 29.10.2019 within statutory period but failed to submit financial statements within mandatory 30-day window per Section 137 of Companies Act. Court determined that administrative circular dated 29.10.2019 extending filing deadline to 30.11.2019 cannot override statutory timeframes. Circular only applied to companies with ROC-approved AGM extensions beyond September 30. Penalty imposed from 30.10.2019 was upheld as legally valid since administrative directives cannot amend statutory provisions. Court emphasized that Section 403 mandates penalties of minimum Rs.100/day for late filings without discretionary waiver options.
HC ruled against petitioner companies seeking refund of additional fees charged for delayed financial statement filing. Companies held AGM on 29.10.2019 within statutory period but failed to submit financial statements within mandatory 30-day window per Section 137 of Companies Act. Court determined that administrative circular dated 29.10.2019 extending filing deadline to 30.11.2019 cannot override statutory timeframes. Circular only applied to companies with ROC-approved AGM extensions beyond September 30. Penalty imposed from 30.10.2019 was upheld as legally valid since administrative directives cannot amend statutory provisions. Court emphasized that Section 403 mandates penalties of minimum Rs.100/day for late filings without discretionary waiver options.
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