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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
HC allowed the petition challenging CIT's denial of exemption u/s 12A. The Court found genuine hardship in delayed filing of Audit Report in Form 10B for AY 2020-21, which was submitted 76 days beyond statutory deadline. Directing liberal interpretation of procedural requirements, the HC set aside CIT's order and mandated reconsideration of the Audit Report. The Commissioner is instructed to grant consequential relief, treat the delayed filing as within prescribed timelines, and re-examine the merit of the Audit Report under Section 12A read with Rule 17B, potentially modifying the Section 143 intimation accordingly.
HC allowed the petition challenging CIT's denial of exemption u/s 12A. The Court found genuine hardship in delayed filing of Audit Report in Form 10B for AY 2020-21, which was submitted 76 days beyond statutory deadline. Directing liberal interpretation of procedural requirements, the HC set aside CIT's order and mandated reconsideration of the Audit Report. The Commissioner is instructed to grant consequential relief, treat the delayed filing as within prescribed timelines, and re-examine the merit of the Audit Report under Section 12A read with Rule 17B, potentially modifying the Section 143 intimation accordingly.
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