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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ITAT allowed the appeal, holding that for AY 2019-20 the amendment introduced by Finance Act 2020 requiring filing of Form 10B at least one month prior to the due date of return was inapplicable. The assessee had filed Form 10B along with the return within the due date, satisfying the then-prevailing statutory requirement. Therefore, denial of exemption under section 11 on the ground of belated upload and non-attachment of registration documents under section 12A was unjustified. The order of CIT(A) was set aside and the AO directed to grant exemption as per law.
ITAT allowed the appeal, holding that for AY 2019-20 the amendment introduced by Finance Act 2020 requiring filing of Form 10B at least one month prior to the due date of return was inapplicable. The assessee had filed Form 10B along with the return within the due date, satisfying the then-prevailing statutory requirement. Therefore, denial of exemption under section 11 on the ground of belated upload and non-attachment of registration documents under section 12A was unjustified. The order of CIT(A) was set aside and the AO directed to grant exemption as per law.
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