Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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