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, holding that the delay in filing the return was attributable to the petitioner's Chartered Accountant being pre-occupied with a family ceremony and constituted a genuine hardship; the audit report had been duly certified and the assessee's losses were undisputed. The Court concluded that entitlement to the statutory benefit is procedural and cannot be forfeited on mere technicalities where a bona fide explanation exists. The HC set aside the respondent's order and remanded the matter with a direction to consider and pass a fresh order under Sec. 119(2)(b) of the Act, condoning the delay in filing the income-tax return.
The HC allowed the petition, holding that the delay in filing the return was attributable to the petitioner's Chartered Accountant being pre-occupied with a family ceremony and constituted a genuine hardship; the audit report had been duly certified and the assessee's losses were undisputed. The Court concluded that entitlement to the statutory benefit is procedural and cannot be forfeited on mere technicalities where a bona fide explanation exists. The HC set aside the respondent's order and remanded the matter with a direction to consider and pass a fresh order under Sec. 119(2)(b) of the Act, condoning the delay in filing the income-tax return.
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