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 petitioner's application under Section 119(2)(b), condoning one-day delay in ITR filing for AY 2016-17. The court found genuine hardship in electronic filing process, noting petitioner had already uploaded critical documents and commenced return submission. Recognizing statutory authorities' duty to provide relief in meritorious cases, the HC directed relaxation of strict timelines, emphasizing that technical impediments should not prejudice taxpayers' substantive compliance obligations.
HC allowed petitioner's application under Section 119(2)(b), condoning one-day delay in ITR filing for AY 2016-17. The court found genuine hardship in electronic filing process, noting petitioner had already uploaded critical documents and commenced return submission. Recognizing statutory authorities' duty to provide relief in meritorious cases, the HC directed relaxation of strict timelines, emphasizing that technical impediments should not prejudice taxpayers' substantive compliance obligations.
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