Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
Scientific Research approval for Sikshya O Anusandhan under section 35(1)(ii) granted subject to reporting, certification, and compliance requirements...
The dominant issue was whether rejection of the taxpayer's application under s. 119(2)(b) for condonation of an eight-minute delay in e-filing the return was legally sustainable, resulting in denial of carry-forward of losses. The record showed the tax audit report was uploaded within time and the taxpayer logged into the portal before midnight, with the return uploaded only eight minutes after the deadline. Given the minimal delay and the disproportionate hardship of disallowing substantial carried-forward losses solely for such marginal default, the delay was required to be condoned and the rejection order could not stand; delay condoned. - HC
The dominant issue was whether rejection of the taxpayer's application under s. 119(2)(b) for condonation of an eight-minute delay in e-filing the return was legally sustainable, resulting in denial of carry-forward of losses. The record showed the tax audit report was uploaded within time and the taxpayer logged into the portal before midnight, with the return uploaded only eight minutes after the deadline. Given the minimal delay and the disproportionate hardship of disallowing substantial carried-forward losses solely for such marginal default, the delay was required to be condoned and the rejection order could not stand; delay condoned. - HC
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