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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4826 
Join Channel 
