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 quashed and set aside the impugned order of Respondent No.1 issued under Section 119(2)(b), and condoned an 84-day delay in filing Form No.10B. Consequently, the petitioner is not to be deprived of exemption under Section 11 on the ground of the delayed audit report; the denial of benefits was held to cause genuine hardship and was therefore inappropriate. The court found the authority's refusal unduly pedantic, endorsing a justice-oriented discretionary exercise consistent with prior judicial approaches, and directed that the petitioner's belated Form No.10B be treated as valid for purposes of claiming Section 11 exemption.
The HC quashed and set aside the impugned order of Respondent No.1 issued under Section 119(2)(b), and condoned an 84-day delay in filing Form No.10B. Consequently, the petitioner is not to be deprived of exemption under Section 11 on the ground of the delayed audit report; the denial of benefits was held to cause genuine hardship and was therefore inappropriate. The court found the authority's refusal unduly pedantic, endorsing a justice-oriented discretionary exercise consistent with prior judicial approaches, and directed that the petitioner's belated Form No.10B be treated as valid for purposes of claiming Section 11 exemption.
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