Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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