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 quashed and set aside the impugned order dated 26 March 2025 passed by the respondent under s.119(2)(b) and condoned a delay of 133 days in electronically filing Form No.10B for AY 2019-20. The court found the lapse was inadvertent, not deliberate or mala fide, attributable to the petitioner's auditor, and the petitioner-a charitable trust running educational institutions-had otherwise complied with statutory requirements and obtained the audit report timely. Refusal to condone would have caused grave injustice and financial hardship. Consequently, the denial of exemption under s.11 premised solely on the technical non-filing was effectively set aside and relief granted.
The HC quashed and set aside the impugned order dated 26 March 2025 passed by the respondent under s.119(2)(b) and condoned a delay of 133 days in electronically filing Form No.10B for AY 2019-20. The court found the lapse was inadvertent, not deliberate or mala fide, attributable to the petitioner's auditor, and the petitioner-a charitable trust running educational institutions-had otherwise complied with statutory requirements and obtained the audit report timely. Refusal to condone would have caused grave injustice and financial hardship. Consequently, the denial of exemption under s.11 premised solely on the technical non-filing was effectively set aside and relief granted.
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