Appeal allows set-aside of transfer pricing adjustment imputing notional interest on integrated intercompany receivables after net margin exceeded com...
The HC directed respondents to permit the petitioner to file income-tax returns for AYs 2021-22 to 2023-24 in Form ITR-2 by manual mode and to treat such filings as returns filed under Section 139(1) of the IT Act. The court ordered respondents to accept, until the e-filing system is amended by the CBDT, manual ITR-2 filings for all private discretionary trusts. The HC declined to mandate further systemic changes while noting the CBDT's ongoing adjustments. The HC also recognized that private discretionary trusts are entitled to be assessed as individual persons for income-tax purposes, in line with established departmental position.
The HC directed respondents to permit the petitioner to file income-tax returns for AYs 2021-22 to 2023-24 in Form ITR-2 by manual mode and to treat such filings as returns filed under Section 139(1) of the IT Act. The court ordered respondents to accept, until the e-filing system is amended by the CBDT, manual ITR-2 filings for all private discretionary trusts. The HC declined to mandate further systemic changes while noting the CBDT's ongoing adjustments. The HC also recognized that private discretionary trusts are entitled to be assessed as individual persons for income-tax purposes, in line with established departmental position.
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