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 Tribunal applied the doctrine of substantial compliance and beneficial interpretation where the assessee clearly exercised the option for the concessional tax regime and paid tax at that rate, but Form 10-IC upload failed due to an ITBA portal glitch and staff error; treating the filing of Form 10-IC as directory rather than mandatory, the Tribunal held that denial of relief solely for late filing was inappropriate and directed the assessing officer to compute tax under section 115BAA for A.Y. 2024-25, with interest-related contention treated as consequential.
The Tribunal applied the doctrine of substantial compliance and beneficial interpretation where the assessee clearly exercised the option for the concessional tax regime and paid tax at that rate, but Form 10-IC upload failed due to an ITBA portal glitch and staff error; treating the filing of Form 10-IC as directory rather than mandatory, the Tribunal held that denial of relief solely for late filing was inappropriate and directed the assessing officer to compute tax under section 115BAA for A.Y. 2024-25, with interest-related contention treated as consequential.
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