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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Delay in filing Form 10 was condoned where refusal would have exposed the assessee to tax liability and caused grave hardship despite no benefit arising from the delay. The High Court accepted the explanation that the default resulted from the Chartered Accountant's failure, supported by affidavit, and noted that the same officer had already condoned the delay in filing the return of income. On these facts, the rejection of condonation was unsustainable. The impugned order was quashed, the delay in Form 10 was condoned, and the return was directed to be processed in accordance with law.
Delay in filing Form 10 was condoned where refusal would have exposed the assessee to tax liability and caused grave hardship despite no benefit arising from the delay. The High Court accepted the explanation that the default resulted from the Chartered Accountant's failure, supported by affidavit, and noted that the same officer had already condoned the delay in filing the return of income. On these facts, the rejection of condonation was unsustainable. The impugned order was quashed, the delay in Form 10 was condoned, and the return was directed to be processed in accordance with law.
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