Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
HC held that the delay in filing Form No. 9A was condoned under Section 119(2)(b) of the IT Act as a bona fide mistake arising from reliance on a misprint in a widely relied commercial bare act publication. The court found that the Assessing Officer ought to have condoned the delay, that the Petitioner did not derive any advantage from the delay, and that refusal would cause grave hardship. Consequently, the Petitioner is entitled to the benefit of Sections 11 and 12, and the denial of exemptions on account of delayed filing was set aside.
HC held that the delay in filing Form No. 9A was condoned under Section 119(2)(b) of the IT Act as a bona fide mistake arising from reliance on a misprint in a widely relied commercial bare act publication. The court found that the Assessing Officer ought to have condoned the delay, that the Petitioner did not derive any advantage from the delay, and that refusal would cause grave hardship. Consequently, the Petitioner is entitled to the benefit of Sections 11 and 12, and the denial of exemptions on account of delayed filing was set aside.
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