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 writ petition and directed that the petitioner may file a fresh application for condonation of delay under s.119(2)(b) of the Act; the respondent is directed to consider such application on its merits and in accordance with law. The court observed the statutory requirement that condonation grounds demonstrate "genuine hardship," noted prior opportunities given to the petitioner to furnish supporting documents, and recorded deficiencies in the petitioner's earlier submissions, but nevertheless permitted renewal of the statutory remedy rather than dismissing statutory relief outright. No procedural infirmity requiring quashing of the condonation process was found.
The HC allowed the writ petition and directed that the petitioner may file a fresh application for condonation of delay under s.119(2)(b) of the Act; the respondent is directed to consider such application on its merits and in accordance with law. The court observed the statutory requirement that condonation grounds demonstrate "genuine hardship," noted prior opportunities given to the petitioner to furnish supporting documents, and recorded deficiencies in the petitioner's earlier submissions, but nevertheless permitted renewal of the statutory remedy rather than dismissing statutory relief outright. No procedural infirmity requiring quashing of the condonation process was found.
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