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 determined that online tax filing utilities cannot inherently prevent taxpayers from making legitimate claims under Section 87A of the Income Tax Act. While referencing similar precedents where manual returns were permitted when electronic filing systems were restrictive, the court held that assessees cannot be barred from making statutory claims, whether filing online or manually. The court directed modification of the online utility to allow Section 87A rebate claims for AY 2024-25 and subsequent years, including revised returns under Section 139(5). However, the court clarified that the actual eligibility determination of Section 87A claims remains with tax authorities during return processing, maintaining their statutory authority to examine claim validity.
HC determined that online tax filing utilities cannot inherently prevent taxpayers from making legitimate claims under Section 87A of the Income Tax Act. While referencing similar precedents where manual returns were permitted when electronic filing systems were restrictive, the court held that assessees cannot be barred from making statutory claims, whether filing online or manually. The court directed modification of the online utility to allow Section 87A rebate claims for AY 2024-25 and subsequent years, including revised returns under Section 139(5). However, the court clarified that the actual eligibility determination of Section 87A claims remains with tax authorities during return processing, maintaining their statutory authority to examine claim validity.
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