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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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
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