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 dismissed the writ petition challenging rejection of condonation of delay in filing ITR for AY 2018-19. It held that a 30-month delay could not be excused under the "genuine hardship" proviso merely on the generic plea of disputes between directors and financial difficulty, particularly when the company remained a going concern and had duly filed ITRs for AYs 2017-18 and 2019-20. The Court found no documentary proof of the alleged director dispute and concluded that statutory obligations cannot be deferred on such assertions. Relying on precedent, the HC held that liberal construction of "genuine hardship" cannot extend to condoning such inordinate, unjustified delay.
HC dismissed the writ petition challenging rejection of condonation of delay in filing ITR for AY 2018-19. It held that a 30-month delay could not be excused under the "genuine hardship" proviso merely on the generic plea of disputes between directors and financial difficulty, particularly when the company remained a going concern and had duly filed ITRs for AYs 2017-18 and 2019-20. The Court found no documentary proof of the alleged director dispute and concluded that statutory obligations cannot be deferred on such assertions. Relying on precedent, the HC held that liberal construction of "genuine hardship" cannot extend to condoning such inordinate, unjustified delay.
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