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 ITAT condoned the 2,455-day delay in instituting appeals to the CIT(A), holding that reasonable cause excused the delay and it was not deliberate nor beneficial to the assessee. The Tribunal restored the dispute to the file of the ld. Assessing Officer (TDS) for limited verification and directed deletion of any section 234E fees levied for defaults prior to 01.06.2015. Section 234E fees assessed for the period from 01.06.2015 until actual filing of the TDS return (15.05.2016) are to be sustained. The appeals are otherwise disposed of in accordance with these directions.
The ITAT condoned the 2,455-day delay in instituting appeals to the CIT(A), holding that reasonable cause excused the delay and it was not deliberate nor beneficial to the assessee. The Tribunal restored the dispute to the file of the ld. Assessing Officer (TDS) for limited verification and directed deletion of any section 234E fees levied for defaults prior to 01.06.2015. Section 234E fees assessed for the period from 01.06.2015 until actual filing of the TDS return (15.05.2016) are to be sustained. The appeals are otherwise disposed of in accordance with these directions.
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