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External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
ITAT allowed the appeal of a religious institution managed by Telangana Endowment Department challenging denial of exemption under Section 11. The Assessing Officer denied exemption for failure to file audit report in Form 10BB by the due date of 31/10/2023, though the appellant filed it on 28/11/2023 with a 28-day delay. The Tribunal held that despite the delay, since the audit report was available before the AO passed the assessment order under Section 143(1) on 19/11/2024, exemption should not be denied. Following precedent, the Tribunal ruled that Form 10BB filing requirements are directory rather than mandatory when the audit report is available during assessment proceedings and legal requirements are substantially complied with.
ITAT allowed the appeal of a religious institution managed by Telangana Endowment Department challenging denial of exemption under Section 11. The Assessing Officer denied exemption for failure to file audit report in Form 10BB by the due date of 31/10/2023, though the appellant filed it on 28/11/2023 with a 28-day delay. The Tribunal held that despite the delay, since the audit report was available before the AO passed the assessment order under Section 143(1) on 19/11/2024, exemption should not be denied. Following precedent, the Tribunal ruled that Form 10BB filing requirements are directory rather than mandatory when the audit report is available during assessment proceedings and legal requirements are substantially complied with.
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