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 petition challenging CIT(E)'s rejection of delay condonation for Form 10B filing. The court held that while "genuine hardship" may not have a broad interpretation, authorities must exercise discretionary powers judiciously when an assessee establishes legitimate circumstances preventing timely compliance. The HC directed CIT(E) to issue an order condoning the thirty-day delay in filing Form 10B for Assessment Year 2022-23, finding the original rejection erroneous and emphasizing that administrative powers must be exercised with due consideration of substantive hardship.
HC allowed the petition challenging CIT(E)'s rejection of delay condonation for Form 10B filing. The court held that while "genuine hardship" may not have a broad interpretation, authorities must exercise discretionary powers judiciously when an assessee establishes legitimate circumstances preventing timely compliance. The HC directed CIT(E) to issue an order condoning the thirty-day delay in filing Form 10B for Assessment Year 2022-23, finding the original rejection erroneous and emphasizing that administrative powers must be exercised with due consideration of substantive hardship.
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