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 granted relief to petitioner seeking condonation of delay in filing revised income tax return under s.139(5). Court considered multiple factors including director's personal circumstances (family issues, mother's illness requiring spine surgeries), company's operational challenges (ERP implementation, high staff attrition), and management's inability to detect incorrect figures until s.142(1) notice. Finding these human factors and fortuitous circumstances compelling, HC quashed original order dated 21/09/2023. Respondents directed to accept returns with applicable penalties, fees and interest within two weeks of order copy availability. Court emphasized necessity of considering human elements when evaluating statutory time limit compliance under IT Act.
HC granted relief to petitioner seeking condonation of delay in filing revised income tax return under s.139(5). Court considered multiple factors including director's personal circumstances (family issues, mother's illness requiring spine surgeries), company's operational challenges (ERP implementation, high staff attrition), and management's inability to detect incorrect figures until s.142(1) notice. Finding these human factors and fortuitous circumstances compelling, HC quashed original order dated 21/09/2023. Respondents directed to accept returns with applicable penalties, fees and interest within two weeks of order copy availability. Court emphasized necessity of considering human elements when evaluating statutory time limit compliance under IT Act.
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