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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ITAT upheld grant of the concessional tax regime under section 115BAA where Form 10-IC was filed after the due date but had been furnished and was available when the return was processed. The assessee had disclosed the option in the return and the intimation under section 143(1) also recorded that option, while no other condition for the concessional rate was shown to be unfulfilled. On that basis, the CPC was required to consider the form during processing. The appellate direction to recompute tax by allowing the section 115BAA benefit was sustained and the Revenue's challenge was rejected.
ITAT upheld grant of the concessional tax regime under section 115BAA where Form 10-IC was filed after the due date but had been furnished and was available when the return was processed. The assessee had disclosed the option in the return and the intimation under section 143(1) also recorded that option, while no other condition for the concessional rate was shown to be unfulfilled. On that basis, the CPC was required to consider the form during processing. The appellate direction to recompute tax by allowing the section 115BAA benefit was sustained and the Revenue's challenge was rejected.
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