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 and set aside the impugned order rejecting condonation of delay in filing the Return of Income for A.Y. 2024-25. The court held that reliance on professional advice does not preclude genuine hardship or errors causing delay. It clarified that proof of deduction claim under section 80IBA is not required at the condonation stage but during assessment, which depends on acceptance of the return. The court emphasized a liberal interpretation of "genuine hardship," noting refusal to condone delay could unjustly bar a meritorious claim. Condoning the delay enables adjudication on merits rather than dismissal on technical grounds. Consequently, the delay in filing the return was condoned to prevent substantial prejudice to the petitioner's rights.
The HC allowed the petition and set aside the impugned order rejecting condonation of delay in filing the Return of Income for A.Y. 2024-25. The court held that reliance on professional advice does not preclude genuine hardship or errors causing delay. It clarified that proof of deduction claim under section 80IBA is not required at the condonation stage but during assessment, which depends on acceptance of the return. The court emphasized a liberal interpretation of "genuine hardship," noting refusal to condone delay could unjustly bar a meritorious claim. Condoning the delay enables adjudication on merits rather than dismissal on technical grounds. Consequently, the delay in filing the return was condoned to prevent substantial prejudice to the petitioner's rights.
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