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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
The HC quashed the order of the PCIT denying the benefit of Section 115BAA due to non-filing of Form 10-IC prior to the ITR, holding that the statutory discretion under Section 119(2)(b) must be exercised liberally to mitigate genuine hardship. The petitioner's demonstrated personal hardships, including successive family deaths, constituted sufficient cause for condonation of delay. The court emphasized that procedural delays should not defeat substantial justice, especially where the assessee's intent to claim the concessional tax benefit was clear. It held that filing Form 10-IC before the return is not mandatory and the delay in filing can be condoned if genuine hardship is established. Consequently, the respondent was directed to condone the delay and accept the Form 10-IC, thereby allowing the assessee's appeal and enabling them to avail the concessional rate under Section 115BAA.
The HC quashed the order of the PCIT denying the benefit of Section 115BAA due to non-filing of Form 10-IC prior to the ITR, holding that the statutory discretion under Section 119(2)(b) must be exercised liberally to mitigate genuine hardship. The petitioner's demonstrated personal hardships, including successive family deaths, constituted sufficient cause for condonation of delay. The court emphasized that procedural delays should not defeat substantial justice, especially where the assessee's intent to claim the concessional tax benefit was clear. It held that filing Form 10-IC before the return is not mandatory and the delay in filing can be condoned if genuine hardship is established. Consequently, the respondent was directed to condone the delay and accept the Form 10-IC, thereby allowing the assessee's appeal and enabling them to avail the concessional rate under Section 115BAA.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
