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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Approval under section 80G cannot be denied merely because a trust deed contains religious objects or some religious activity is shown, since section 80G(5B) permits religious expenditure up to five per cent of total income in the relevant previous year. Rejection based only on the religious nature of the objects and activities, without a finding that the statutory limit was exceeded, is unsustainable. The matter was set aside and remanded for a categorical finding on the statutory threshold and a fresh decision after hearing.
Approval under section 80G cannot be denied merely because a trust deed contains religious objects or some religious activity is shown, since section 80G(5B) permits religious expenditure up to five per cent of total income in the relevant previous year. Rejection based only on the religious nature of the objects and activities, without a finding that the statutory limit was exceeded, is unsustainable. The matter was set aside and remanded for a categorical finding on the statutory threshold and a fresh decision after hearing.
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