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 allowed the assessee the concessional rate under s.115BAA despite non-filing of Form 10-IC before the return due date, holding the form's filing requirement to be directory rather than mandatory. The Tribunal concluded that procedural lapse alone cannot defeat a substantive statutory benefit and directed the Revenue to grant the concessional tax treatment, noting administrative flexibility reflected in earlier CBDT extensions and Tribunal precedents where similar procedural defaults did not disentitle claimants. Result: appeal allowed in favour of the assessee; Revenue directed to compute tax applying s.115BAA and grant consequential relief.
ITAT allowed the assessee the concessional rate under s.115BAA despite non-filing of Form 10-IC before the return due date, holding the form's filing requirement to be directory rather than mandatory. The Tribunal concluded that procedural lapse alone cannot defeat a substantive statutory benefit and directed the Revenue to grant the concessional tax treatment, noting administrative flexibility reflected in earlier CBDT extensions and Tribunal precedents where similar procedural defaults did not disentitle claimants. Result: appeal allowed in favour of the assessee; Revenue directed to compute tax applying s.115BAA and grant consequential relief.
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