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 petition filed u/s 119(2)(b) of the IT Act, holding that successive resignations of key accounts personnel at the petitioner-company's remote location constituted reasonable and sufficient cause for delay in filing the return for AY 2024-25. HC found that the non-filing within the statutory deadline occurred despite exercise of ordinary business care and prudence and was beyond the petitioner's control. The impugned order dated 18.08.2025 passed by the PCIT rejecting condonation of delay was quashed. HC directed the concerned authority to treat the return and audit report for AY 2024-25 as having been filed within the prescribed period and to grant all consequential benefits and reliefs in accordance with the IT Act and applicable circulars/notifications.
HC allowed the petition filed u/s 119(2)(b) of the IT Act, holding that successive resignations of key accounts personnel at the petitioner-company's remote location constituted reasonable and sufficient cause for delay in filing the return for AY 2024-25. HC found that the non-filing within the statutory deadline occurred despite exercise of ordinary business care and prudence and was beyond the petitioner's control. The impugned order dated 18.08.2025 passed by the PCIT rejecting condonation of delay was quashed. HC directed the concerned authority to treat the return and audit report for AY 2024-25 as having been filed within the prescribed period and to grant all consequential benefits and reliefs in accordance with the IT Act and applicable circulars/notifications.
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