Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
HC allowed the petition challenging the denial of deduction under Section 80P(2)(a)(i). The court found that the tax authority erroneously rejected the society's application to condone a two-day delay in return filing without adequately considering genuine hardship. The respondent failed to recognize the temporary administrative changes and ignored the CBDT circular providing discretionary powers to condone minor delays. The HC directed the respondents to pass a fresh order within twelve weeks, condoning the two-day delay and processing the income return, thereby enabling the petitioner to claim the statutory deduction.
HC allowed the petition challenging the denial of deduction under Section 80P(2)(a)(i). The court found that the tax authority erroneously rejected the society's application to condone a two-day delay in return filing without adequately considering genuine hardship. The respondent failed to recognize the temporary administrative changes and ignored the CBDT circular providing discretionary powers to condone minor delays. The HC directed the respondents to pass a fresh order within twelve weeks, condoning the two-day delay and processing the income return, thereby enabling the petitioner to claim the statutory deduction.
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