Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Under section 119(2)(b), delay in filing a return for refund must be examined on reasonable cause, genuine hardship, and any indication of tax evasion. The petitioner supported delayed filing with medical records showing illness of the working partner, and the Court held that this explanation required proper consideration as genuine hardship. Because the return was filed only to claim TDS refund and the treatment documents were not considered, the rejection was found mechanical and erroneous. The condonation refusal was set aside, and the return was directed to be treated as filed within time.
Under section 119(2)(b), delay in filing a return for refund must be examined on reasonable cause, genuine hardship, and any indication of tax evasion. The petitioner supported delayed filing with medical records showing illness of the working partner, and the Court held that this explanation required proper consideration as genuine hardship. Because the return was filed only to claim TDS refund and the treatment documents were not considered, the rejection was found mechanical and erroneous. The condonation refusal was set aside, and the return was directed to be treated as filed within time.
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