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 set aside AO's denial of exemption under Section 11 for charitable trust due to 14-day delay in filing Form 10B audit report and mismatched registration details between ITR and Form 10AC. Tribunal held that minor procedural delays cannot justify denial of exemption, particularly when Form 10B was available with department before Section 143(1) notice issuance. Regarding registration detail mismatch, ITAT noted this resulted from tax consultant error and should not warrant exemption withdrawal when AO could verify Section 12A registration through accessible Form 10AC. Matter remanded to CIT(A) for verification of actual filing dates and registration details, directing appropriate relief if assessee filed Form 10B before notice issuance. Appeal allowed for statistical purposes pending CIT(A)'s verification and fresh determination.
ITAT set aside AO's denial of exemption under Section 11 for charitable trust due to 14-day delay in filing Form 10B audit report and mismatched registration details between ITR and Form 10AC. Tribunal held that minor procedural delays cannot justify denial of exemption, particularly when Form 10B was available with department before Section 143(1) notice issuance. Regarding registration detail mismatch, ITAT noted this resulted from tax consultant error and should not warrant exemption withdrawal when AO could verify Section 12A registration through accessible Form 10AC. Matter remanded to CIT(A) for verification of actual filing dates and registration details, directing appropriate relief if assessee filed Form 10B before notice issuance. Appeal allowed for statistical purposes pending CIT(A)'s verification and fresh determination.
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