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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Where the online return-filing utility prevented a claim of set-off under s.70(2), the Court held that assessees cannot be denied a lawful claim merely because the electronic utility does not permit the prescribed computation, consistent with prior binding precedents. It directed the tax administration to modify the utility to allow the assessee to first set off STCL (STT paid) against STCG (non-STT paid) and only thereafter against STCG (STT paid). Failing timely modification, the authority was ordered to accept and process the revised return for AY 2025-26 in paper form as a valid return under s.139(5), notwithstanding the statutory e-filing mandate. - HC
Where the online return-filing utility prevented a claim of set-off under s.70(2), the Court held that assessees cannot be denied a lawful claim merely because the electronic utility does not permit the prescribed computation, consistent with prior binding precedents. It directed the tax administration to modify the utility to allow the assessee to first set off STCL (STT paid) against STCG (non-STT paid) and only thereafter against STCG (STT paid). Failing timely modification, the authority was ordered to accept and process the revised return for AY 2025-26 in paper form as a valid return under s.139(5), notwithstanding the statutory e-filing mandate. - HC
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