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 held that the denial of benefits under Sections 11 and 12 for delayed e-filing of Form 10B was unjustified and that the application for condonation of delay ought to have been allowed. The court found no mala fides imputable to the petitioner; the delay was attributable to an accident involving staff of the engaged CA firm and thus excusable. An uncontroverted affidavit explaining the delay was accepted as true. Given the petitioner's charitable status and long-standing public charitable activities, the HC concluded that equity warranted condonation; the impugned rejection was quashed and the petitioner entitled to relief notwithstanding the technical delay.
The HC held that the denial of benefits under Sections 11 and 12 for delayed e-filing of Form 10B was unjustified and that the application for condonation of delay ought to have been allowed. The court found no mala fides imputable to the petitioner; the delay was attributable to an accident involving staff of the engaged CA firm and thus excusable. An uncontroverted affidavit explaining the delay was accepted as true. Given the petitioner's charitable status and long-standing public charitable activities, the HC concluded that equity warranted condonation; the impugned rejection was quashed and the petitioner entitled to relief notwithstanding the technical delay.
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