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, in terms of Notification No. 05/2022 dated 29-07-2022, the date of dispatch of the duly signed ITR-V by Speed Post is the relevant date for determining the 30-day e-verification period from electronic transmission of the return. The assessee dispatched ITR-V on 21-08-2023, which falls within 30 days from 24-07-2023, rendering the return deemed to be filed within the due date under s.139(1). Accordingly, ITAT directed CPC to allow the assessee's option for the new tax regime. The assessee's appeal was allowed.
ITAT held that, in terms of Notification No. 05/2022 dated 29-07-2022, the date of dispatch of the duly signed ITR-V by Speed Post is the relevant date for determining the 30-day e-verification period from electronic transmission of the return. The assessee dispatched ITR-V on 21-08-2023, which falls within 30 days from 24-07-2023, rendering the return deemed to be filed within the due date under s.139(1). Accordingly, ITAT directed CPC to allow the assessee's option for the new tax regime. The assessee's appeal was allowed.
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