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 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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