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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Delayed filing of Form 10IC was treated as a procedural lapse where the assessee had already exercised the option for the concessional tax regime under section 115BAA in the return of income and computed tax accordingly. The Tribunal viewed Form 10IC as a mode of intimating the option, not an additional substantive when eligibility and compliance with the provision were not in dispute. The matter was remanded to the Assessing Officer to verify the filed form and grant the concessional rate in accordance with law.
Delayed filing of Form 10IC was treated as a procedural lapse where the assessee had already exercised the option for the concessional tax regime under section 115BAA in the return of income and computed tax accordingly. The Tribunal viewed Form 10IC as a mode of intimating the option, not an additional substantive when eligibility and compliance with the provision were not in dispute. The matter was remanded to the Assessing Officer to verify the filed form and grant the concessional rate in accordance with law.
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