Head Office cost allocation requires prescribed transfer-pricing methods; treaty ceilings bar surcharge and cess, while duplicate taxation is excluded...
Cost-to-cost reimbursement of seconded employees is not service consideration; transfer-pricing markup was deleted and amalgamation amortisation allow...
Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmar...
Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated en...
Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unch...
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Condonation of a 30-day delay in furnishing Form No. 10B for charitable-exemption purposes may be granted under section 119(2)(b) where refusal would cause genuine hardship. Genuine hardship must be construed liberally, with substantial justice preferred over technical non-compliance, absent deliberate delay, culpable negligence or mala fides. A bona fide misunderstanding of an advanced filing due date during the COVID-19 period, coupled with filing before the extended return due date, supported condonation. A pending condonation application did not require the charitable institution to await its disposal. Form No. 10B was treated as timely filed, and the return was to be processed accordingly.
Condonation of a 30-day delay in furnishing Form No. 10B for charitable-exemption purposes may be granted under section 119(2)(b) where refusal would cause genuine hardship. Genuine hardship must be construed liberally, with substantial justice preferred over technical non-compliance, absent deliberate delay, culpable negligence or mala fides. A bona fide misunderstanding of an advanced filing due date during the COVID-19 period, coupled with filing before the extended return due date, supported condonation. A pending condonation application did not require the charitable institution to await its disposal. Form No. 10B was treated as timely filed, and the return was to be processed accordingly.
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