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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ITAT holds that condonation of delay u/s 119(2)(b) validates the assessee's option under s.115BAA, rendering the sole dispute concerning denial of the concessional 22% rate moot. The Tribunal sets aside the order of the CIT(A) and restores the matter to the file of the AO with directions that the AO: (i) take cognizance of the condonation order dated 11.09.2025 passed by the PCIT u/s 119(2)(b); (ii) verify electronic filing of Form No.10-IC and recompute tax liability at 22% u/s 115BAA; and (iii) afford the assessee an opportunity of being heard before giving effect to these directions. The assessee's appeal is allowed for statistical purposes.
ITAT holds that condonation of delay u/s 119(2)(b) validates the assessee's option under s.115BAA, rendering the sole dispute concerning denial of the concessional 22% rate moot. The Tribunal sets aside the order of the CIT(A) and restores the matter to the file of the AO with directions that the AO: (i) take cognizance of the condonation order dated 11.09.2025 passed by the PCIT u/s 119(2)(b); (ii) verify electronic filing of Form No.10-IC and recompute tax liability at 22% u/s 115BAA; and (iii) afford the assessee an opportunity of being heard before giving effect to these directions. The assessee's appeal is allowed for statistical purposes.
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