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 held that delay of 19 days in uploading Form 10BB, though filed before the return of income and available at the time of processing, was merely procedural and not fatal to the assessee's claim of exemption u/s 11 and 12. It ruled that even if the assessee had not approached the competent authority u/s 119, the CIT(A), exercising appellate powers u/s 251, was competent to condone such delay. ITAT condoned the delay, set aside the denial of exemption, and directed the AO to consider the audit report and decide the exemption claim afresh in accordance with law.
ITAT held that delay of 19 days in uploading Form 10BB, though filed before the return of income and available at the time of processing, was merely procedural and not fatal to the assessee's claim of exemption u/s 11 and 12. It ruled that even if the assessee had not approached the competent authority u/s 119, the CIT(A), exercising appellate powers u/s 251, was competent to condone such delay. ITAT condoned the delay, set aside the denial of exemption, and directed the AO to consider the audit report and decide the exemption claim afresh in accordance with law.
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