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 affirmed that once Form No. 10EE is validly furnished for a prior assessment year, the option thereby exercised under Rule 21AAA(1) continues to apply to subsequent years and need not be filed afresh annually. Consequently, denial of relief under section 89A of the Income-tax Act on the sole ground that Form No. 10EE was not refiled in the current year is unsustainable. The Tribunal held the filing requirement to be procedural and constative under Rule 21AAA(6), and directed that relief under section 89A be allowed to the assessee, overturning the contrary finding of the lower authority.
ITAT affirmed that once Form No. 10EE is validly furnished for a prior assessment year, the option thereby exercised under Rule 21AAA(1) continues to apply to subsequent years and need not be filed afresh annually. Consequently, denial of relief under section 89A of the Income-tax Act on the sole ground that Form No. 10EE was not refiled in the current year is unsustainable. The Tribunal held the filing requirement to be procedural and constative under Rule 21AAA(6), and directed that relief under section 89A be allowed to the assessee, overturning the contrary finding of the lower authority.
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