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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HC allowed the writ petition filed by the assessee-company, holding that the delay of about 17 months in filing the revised/rectified return of income, based on a revised tax audit report, was satisfactorily explained and attributable to circumstances beyond the assessee's control due to the COVID-19 pandemic. HC noted the assessee's past compliance history, timely filing of the original return for AY 2018-19, and the favourable recommendations of the Jurisdictional AO and Range Head for condonation under s.119(2)(b). HC held that a justice-oriented rather than pedantic approach must govern such applications. Consequently, the impugned order rejecting condonation was quashed and set aside, the delay was condoned, and any demand/recovery/adjustment arising from the intimation u/s 143(1) was directed not to be proceeded with.
HC allowed the writ petition filed by the assessee-company, holding that the delay of about 17 months in filing the revised/rectified return of income, based on a revised tax audit report, was satisfactorily explained and attributable to circumstances beyond the assessee's control due to the COVID-19 pandemic. HC noted the assessee's past compliance history, timely filing of the original return for AY 2018-19, and the favourable recommendations of the Jurisdictional AO and Range Head for condonation under s.119(2)(b). HC held that a justice-oriented rather than pedantic approach must govern such applications. Consequently, the impugned order rejecting condonation was quashed and set aside, the delay was condoned, and any demand/recovery/adjustment arising from the intimation u/s 143(1) was directed not to be proceeded with.
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