Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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The HC quashed and set aside the impugned order under section 119(2)(b), holding that the delay of 295 days in filing Form 10IC was liable to be condoned. The assessee had satisfied all conditions prescribed in the relevant CBDT Circular, including timely filing of the return under section 139(1), opting for taxation under section 115BAA in the ITR-6, and electronic filing of Form 10IC before the prescribed deadline. The Revenue's contention that the Circular was inapplicable due to prior processing of the return under section 143(1) or detection of delay by the AO was rejected as unfounded. Consequently, the court directed the Revenue to process the assessee's return in accordance with law, recognizing the validity of the delayed Form 10IC filing and allowing the assessee to avail the benefits under section 115BAA.
The HC quashed and set aside the impugned order under section 119(2)(b), holding that the delay of 295 days in filing Form 10IC was liable to be condoned. The assessee had satisfied all conditions prescribed in the relevant CBDT Circular, including timely filing of the return under section 139(1), opting for taxation under section 115BAA in the ITR-6, and electronic filing of Form 10IC before the prescribed deadline. The Revenue's contention that the Circular was inapplicable due to prior processing of the return under section 143(1) or detection of delay by the AO was rejected as unfounded. Consequently, the court directed the Revenue to process the assessee's return in accordance with law, recognizing the validity of the delayed Form 10IC filing and allowing the assessee to avail the benefits under section 115BAA.
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