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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ITAT adjudicated a tax dispute concerning return filing delay of 02 seconds. The tribunal held that a minimal technical delay of 02 seconds does not invalidate the return filing. Referencing precedent cases involving similar technical glitches, the tribunal determined that the return filed prior to midnight should be considered timely. The CPC's denial of carry forward loss claim was deemed incorrect. The AO was directed to treat the original return as filed within statutory time limits and consider the revised return for income computation. The Revenue's appeal was consequently dismissed, affirming the assessee's right to file returns without punitive consequences for negligible technical delays.
ITAT adjudicated a tax dispute concerning return filing delay of 02 seconds. The tribunal held that a minimal technical delay of 02 seconds does not invalidate the return filing. Referencing precedent cases involving similar technical glitches, the tribunal determined that the return filed prior to midnight should be considered timely. The CPC's denial of carry forward loss claim was deemed incorrect. The AO was directed to treat the original return as filed within statutory time limits and consider the revised return for income computation. The Revenue's appeal was consequently dismissed, affirming the assessee's right to file returns without punitive consequences for negligible technical delays.
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