Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
A trust's publication and natural dyeing activities did not negate approval where they were intrinsically linked to its objects of livelihood, skill development, training and employment for disadvantaged rural women, artisans and marginalised communities. The Tribunal held that generation of receipts alone did not show a profit motive, especially where expenditure on wages was substantial and income did not exceed expenditure in some years. It also noted the trust's genuineness, existing registration and absence of any diversion of funds or private benefit. The rejection of approval under section 80G(5) was set aside and approval was directed to be granted.
A trust's publication and natural dyeing activities did not negate approval where they were intrinsically linked to its objects of livelihood, skill development, training and employment for disadvantaged rural women, artisans and marginalised communities. The Tribunal held that generation of receipts alone did not show a profit motive, especially where expenditure on wages was substantial and income did not exceed expenditure in some years. It also noted the trust's genuineness, existing registration and absence of any diversion of funds or private benefit. The rejection of approval under section 80G(5) was set aside and approval was directed to be granted.
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