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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ITAT held that for deduction under section 80JJAA the belated filing of the audit report in Form 10DA is directory and procedural, not mandatory. The Tribunal set aside the CIT(A)'s order and allowed the assessee's grounds, directing the AO (CPC) to consider the Form 10DA already filed and to issue an amended intimation accordingly. The matter was remitted to the AO for compliance with this direction, thereby restoring the assessee's entitlement to claim the deduction subject to verification of the belated audit report. The Revenue's rejection based solely on delayed filing of Form 10DA was quashed.
ITAT held that for deduction under section 80JJAA the belated filing of the audit report in Form 10DA is directory and procedural, not mandatory. The Tribunal set aside the CIT(A)'s order and allowed the assessee's grounds, directing the AO (CPC) to consider the Form 10DA already filed and to issue an amended intimation accordingly. The matter was remitted to the AO for compliance with this direction, thereby restoring the assessee's entitlement to claim the deduction subject to verification of the belated audit report. The Revenue's rejection based solely on delayed filing of Form 10DA was quashed.
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