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 quashed the order rejecting the petitioner's application under s119(2)(b) of the Income Tax Act for condonation of delay in filing a corrected return. The petitioner had erroneously clubbed disallowances under s37 in column-23 instead of properly recording them in columns 15 and 18 of Form ITR-6. Since this was merely a presentation error with no impact on taxable income, and was made to facilitate CPC processing for potential refund, the Court held that the tax authority should have condoned the delay. The HC directed respondent to process the revised return filed on 06/09/2019 in accordance with law, emphasizing that the correction was a formality that did not alter the substantive tax position.
The HC quashed the order rejecting the petitioner's application under s119(2)(b) of the Income Tax Act for condonation of delay in filing a corrected return. The petitioner had erroneously clubbed disallowances under s37 in column-23 instead of properly recording them in columns 15 and 18 of Form ITR-6. Since this was merely a presentation error with no impact on taxable income, and was made to facilitate CPC processing for potential refund, the Court held that the tax authority should have condoned the delay. The HC directed respondent to process the revised return filed on 06/09/2019 in accordance with law, emphasizing that the correction was a formality that did not alter the substantive tax position.
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