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 allowed the petitioner's application for condonation of delay in filing audit report during COVID-19 pandemic. The Commissioner's initial rejection was deemed hyper-technical, disregarding the extenuating circumstances. The court recognized the recent amendment to audit report filing requirements and referenced SC's suo motu order extending limitation periods. Considering the minimal 25-day delay and pandemic-related challenges, the HC set aside the previous order and condoned the delay in filing the audit report for the assessment year 2021-2022, thereby providing relief to the petitioner.
HC allowed the petitioner's application for condonation of delay in filing audit report during COVID-19 pandemic. The Commissioner's initial rejection was deemed hyper-technical, disregarding the extenuating circumstances. The court recognized the recent amendment to audit report filing requirements and referenced SC's suo motu order extending limitation periods. Considering the minimal 25-day delay and pandemic-related challenges, the HC set aside the previous order and condoned the delay in filing the audit report for the assessment year 2021-2022, thereby providing relief to the petitioner.
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