Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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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