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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
The HC quashed and set aside the impugned order of Respondent No.1, holding that there was no statutory requirement to file Form No.9A for A.Y. 2015-16 as the mandatory filing obligation was introduced by the Finance Act, 2015 w.e.f. 1.4.2016. The Court found the Applicant had validly exercised the option under clause (2) of the Explanation to s.11(1) within time by disclosures in Form No.10B and its timely return of income, and that denying relief would cause undue hardship and a disproportionate demand. The HC directed the Respondents to reopen and process the Applicant's return in the pending de novo assessment proceedings in accordance with law consistent with this holding.
The HC quashed and set aside the impugned order of Respondent No.1, holding that there was no statutory requirement to file Form No.9A for A.Y. 2015-16 as the mandatory filing obligation was introduced by the Finance Act, 2015 w.e.f. 1.4.2016. The Court found the Applicant had validly exercised the option under clause (2) of the Explanation to s.11(1) within time by disclosures in Form No.10B and its timely return of income, and that denying relief would cause undue hardship and a disproportionate demand. The HC directed the Respondents to reopen and process the Applicant's return in the pending de novo assessment proceedings in accordance with law consistent with this holding.
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