Dependent Agent PE unresolved for lack of factual inquiry; arm's-length distribution accepted; royalty claim rejected; 15% refund interest (Section 24...
Exemption under s.10(23C)(iiiad) upheld; appeal allowed, interest and dividends excluded from annual receipts, disallowance deleted, capital gains exe...
The HC quashed and set aside the impugned order under s.119(2)(b) dated 31 March 2025 and condoned a 70-day delay in filing the audit report in Form No.10B for AY 2020-21, thereby restoring the applicant's benefit under s.11. The court found the earlier preponement of the Form 10B due date (effective AY 2020-21) was inadvertently overlooked by the applicant and its CA, the report having nonetheless been filed with the return. The HC accepted that the trust was functioning without key trustees and permanent accounting staff, and that genuine hardship would ensue if delay were not excused, rendering the denial of exemption unwarranted.
The HC quashed and set aside the impugned order under s.119(2)(b) dated 31 March 2025 and condoned a 70-day delay in filing the audit report in Form No.10B for AY 2020-21, thereby restoring the applicant's benefit under s.11. The court found the earlier preponement of the Form 10B due date (effective AY 2020-21) was inadvertently overlooked by the applicant and its CA, the report having nonetheless been filed with the return. The HC accepted that the trust was functioning without key trustees and permanent accounting staff, and that genuine hardship would ensue if delay were not excused, rendering the denial of exemption unwarranted.
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