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 under s.119(2)(b) and condoned the delay in filing income tax return for AY 2020-21, allowing the petitioner to claim refund belatedly. The court recognized genuine hardship faced by the non-resident petitioner who was prevented from filing returns due to COVID-19 travel restrictions and late deposit of TDS by the property purchaser (M/s. Ashutosh Builders) on 11.06.2022. The petitioner had already furnished income computation with long-term capital gain details in response to the tax authority's notice. The HC determined these circumstances constituted sufficient grounds for condonation of delay under the Income Tax Act provisions.
The HC quashed the order under s.119(2)(b) and condoned the delay in filing income tax return for AY 2020-21, allowing the petitioner to claim refund belatedly. The court recognized genuine hardship faced by the non-resident petitioner who was prevented from filing returns due to COVID-19 travel restrictions and late deposit of TDS by the property purchaser (M/s. Ashutosh Builders) on 11.06.2022. The petitioner had already furnished income computation with long-term capital gain details in response to the tax authority's notice. The HC determined these circumstances constituted sufficient grounds for condonation of delay under the Income Tax Act provisions.
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