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 the petition challenging rejection of condonation application for delayed income tax return filing. Petitioner, a non-resident assessee, failed to file return within prescribed time limit believing no filing obligation existed due to absence of tax liability, and was medically unfit during pendency. Court held that procedural requirements cannot defeat substantive rights when genuine hardship exists, relying on established precedents regarding condonation of delay. HC quashed the impugned order and remanded matter to respondent authority with directions to pass fresh order condoning delay, enabling petitioner to claim legitimate refund of excess tax deducted at source under statutory provisions.
HC allowed the petition challenging rejection of condonation application for delayed income tax return filing. Petitioner, a non-resident assessee, failed to file return within prescribed time limit believing no filing obligation existed due to absence of tax liability, and was medically unfit during pendency. Court held that procedural requirements cannot defeat substantive rights when genuine hardship exists, relying on established precedents regarding condonation of delay. HC quashed the impugned order and remanded matter to respondent authority with directions to pass fresh order condoning delay, enabling petitioner to claim legitimate refund of excess tax deducted at source under statutory provisions.
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