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 ITAT allowed the assessee's appeal, holding that delay in filing Form 10-IC did not disentitle the assessee to concessional taxation under s.115BAA where the form was filed for the first time before the Tribunal and the omission was explained as oversight; other grounds were consequential. The Tribunal directed the assessing officer to grant the benefit of s.115BAA if the assessee satisfies all statutory and procedural prerequisites, distinguishing revenue reliance on a decision where Form 10-IC was not filed even before the Tribunal. The relief is conditional upon fulfillment of all remaining requisite conditions.
The ITAT allowed the assessee's appeal, holding that delay in filing Form 10-IC did not disentitle the assessee to concessional taxation under s.115BAA where the form was filed for the first time before the Tribunal and the omission was explained as oversight; other grounds were consequential. The Tribunal directed the assessing officer to grant the benefit of s.115BAA if the assessee satisfies all statutory and procedural prerequisites, distinguishing revenue reliance on a decision where Form 10-IC was not filed even before the Tribunal. The relief is conditional upon fulfillment of all remaining requisite conditions.
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