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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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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