Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Belated filing of Form 10B was treated as a procedural lapse that should not defeat exemption claims under sections 11 and 12 in the peculiar facts of the case. Relying on the principle that technical defaults should not override substantive entitlement, and following prior precedent, the Tribunal directed the Assessing Officer to treat the trust's Form 10B as filed within time and process the return accordingly. The appeal was thus allowed, with the delayed filing not being permitted to deny the claimed charitable exemption.
Belated filing of Form 10B was treated as a procedural lapse that should not defeat exemption claims under sections 11 and 12 in the peculiar facts of the case. Relying on the principle that technical defaults should not override substantive entitlement, and following prior precedent, the Tribunal directed the Assessing Officer to treat the trust's Form 10B as filed within time and process the return accordingly. The appeal was thus allowed, with the delayed filing not being permitted to deny the claimed charitable exemption.
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