Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
A 13-day delay in filing Form 10-IC for the concessional regime under section 115BAA was condoned because the delay was short, arose from undisputed circumstances linked to the death of the group founder/chairman, and was neither deliberate nor mala fide. The Court treated the benefit under section 115BAA as a substantive statutory entitlement and Form 10-IC as only the procedural mode for exercising that option; a procedural lapse could not defeat eligibility where no dispute existed on the substantive conditions. The refusal to condone was quashed for undue technicality, absence of prejudice to the Revenue, and failure to account for disproportionate hardship.
A 13-day delay in filing Form 10-IC for the concessional regime under section 115BAA was condoned because the delay was short, arose from undisputed circumstances linked to the death of the group founder/chairman, and was neither deliberate nor mala fide. The Court treated the benefit under section 115BAA as a substantive statutory entitlement and Form 10-IC as only the procedural mode for exercising that option; a procedural lapse could not defeat eligibility where no dispute existed on the substantive conditions. The refusal to condone was quashed for undue technicality, absence of prejudice to the Revenue, and failure to account for disproportionate hardship.
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