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 petition, holding that the delay in filing/verifying Form 10B was attributable to the auditor's oversight and abrupt departure, and was bonafide and beyond the Petitioner's control; accordingly the delay is condoned. The impugned denial of exemption under s.11 is set aside to the extent premised on that delay, as such forfeiture would cause undue hardship to a longstanding charitable trust that has otherwise complied with filings. The Court declined to pronounce on alleged mismatches between the return and Form 10B, leaving those factual discrepancies to be examined by the Assessing Officer at assessment/rectification stage.
The HC allowed the petition, holding that the delay in filing/verifying Form 10B was attributable to the auditor's oversight and abrupt departure, and was bonafide and beyond the Petitioner's control; accordingly the delay is condoned. The impugned denial of exemption under s.11 is set aside to the extent premised on that delay, as such forfeiture would cause undue hardship to a longstanding charitable trust that has otherwise complied with filings. The Court declined to pronounce on alleged mismatches between the return and Form 10B, leaving those factual discrepancies to be examined by the Assessing Officer at assessment/rectification stage.
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