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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The dominant issue was whether delay in filing the return could be condoned under section 119(2)(b) on the ground of "genuine hardship." The Court held that ignorance of tax law is no excuse, and the plea of illiteracy did not establish reasonable cause, particularly since the assessee had timely filed the return for an earlier assessment year, indicating awareness of the filing process. Relying on the principle that statutory time limits must be adhered to and extension is not a vested right, the Court found no perversity in the authority's refusal to condone delay and dismissed the writ petition. - HC
The dominant issue was whether delay in filing the return could be condoned under section 119(2)(b) on the ground of "genuine hardship." The Court held that ignorance of tax law is no excuse, and the plea of illiteracy did not establish reasonable cause, particularly since the assessee had timely filed the return for an earlier assessment year, indicating awareness of the filing process. Relying on the principle that statutory time limits must be adhered to and extension is not a vested right, the Court found no perversity in the authority's refusal to condone delay and dismissed the writ petition. - HC
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