Marketing support and subcontracted client contracts: no agency permanent establishment under Article 5 DTAA; arm's-length pricing bars profit attribu...
Transfer pricing comparables selection and working capital adjustment u/r 10B(1)(e)(iii), remanded for recomputation with rejected comparables include...
Rejection of condonation for delayed filing of Form No. 10 and Form No. 10B was held unsustainable where the sole basis was that the condonation application was filed beyond three years from the end of the relevant AY, despite the underlying filing delays being minor (about 38 and 69 days). The authority's acceptance of the explanation for delay in filing the return, the applicant's bona fide pursuit of statutory appellate remedies against the s.143(1) intimation, and the trustee's affidavit explaining inability due to age and health constituted sufficient cause. The impugned orders under s.119(2)(b) were quashed and the delays in filing Forms 10 and 10B were condoned - HC
Rejection of condonation for delayed filing of Form No. 10 and Form No. 10B was held unsustainable where the sole basis was that the condonation application was filed beyond three years from the end of the relevant AY, despite the underlying filing delays being minor (about 38 and 69 days). The authority's acceptance of the explanation for delay in filing the return, the applicant's bona fide pursuit of statutory appellate remedies against the s.143(1) intimation, and the trustee's affidavit explaining inability due to age and health constituted sufficient cause. The impugned orders under s.119(2)(b) were quashed and the delays in filing Forms 10 and 10B were condoned - HC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4816 
Join Channel 
