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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The HC allowed the petition seeking condonation of delay in filing Form 10-IC related to exercising the option under Section 115BAA for AY 2021-22. It was held that the option must be exercised at the time of filing the return under Section 139(1) in the prescribed manner per Rule 21AE. Due to confusion and technical issues, CBDT Circular No. 6/2022 extended the deadline for filing Form 10-IC, effectively relaxing the requirement. The Court directed the respondent to permit the petitioner to file a fresh Form 10-IC for AY 2021 and consider condoning the delay under Section 119(2)(b) to address hardship. The petition was allowed, enabling the petitioner to obtain Form 10-IC for AY 2021 and subsequently apply for condonation of delay for filing the same.
The HC allowed the petition seeking condonation of delay in filing Form 10-IC related to exercising the option under Section 115BAA for AY 2021-22. It was held that the option must be exercised at the time of filing the return under Section 139(1) in the prescribed manner per Rule 21AE. Due to confusion and technical issues, CBDT Circular No. 6/2022 extended the deadline for filing Form 10-IC, effectively relaxing the requirement. The Court directed the respondent to permit the petitioner to file a fresh Form 10-IC for AY 2021 and consider condoning the delay under Section 119(2)(b) to address hardship. The petition was allowed, enabling the petitioner to obtain Form 10-IC for AY 2021 and subsequently apply for condonation of delay for filing the same.
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