Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
A charitable trust assessed as an Association of Persons was held taxable at normal slab rates, not at the maximum marginal rate, because its activities were for the benefit of the public at large and the trustees had no share in the income. The Tribunal treated the issue as covered by co-ordinate Bench decisions on identical facts, including the assessee's own earlier case, and accepted that such a trust cannot be characterised as an AOP with determinate or indeterminate member-shares for the higher rate to apply. The challenge to levy of tax at the maximum marginal rate was allowed.
A charitable trust assessed as an Association of Persons was held taxable at normal slab rates, not at the maximum marginal rate, because its activities were for the benefit of the public at large and the trustees had no share in the income. The Tribunal treated the issue as covered by co-ordinate Bench decisions on identical facts, including the assessee's own earlier case, and accepted that such a trust cannot be characterised as an AOP with determinate or indeterminate member-shares for the higher rate to apply. The challenge to levy of tax at the maximum marginal rate was allowed.
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