Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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Delayed furnishing of Form 10B does not defeat a charitable-trust exemption claim where the audit report is available before processing or completion of assessment and no independent ground exists to disallow application of income. The text applies the principle that a required audit certificate filed before the final assessment order allows the related claim to be considered, distinguishing a decision involving withdrawal from an exemption based on a declaration with an immediate assessment impact. On that basis, verification and allowance of exemption for application of income was affirmed; the Revenue's appeal failed and the cross-objection became academic.
Delayed furnishing of Form 10B does not defeat a charitable-trust exemption claim where the audit report is available before processing or completion of assessment and no independent ground exists to disallow application of income. The text applies the principle that a required audit certificate filed before the final assessment order allows the related claim to be considered, distinguishing a decision involving withdrawal from an exemption based on a declaration with an immediate assessment impact. On that basis, verification and allowance of exemption for application of income was affirmed; the Revenue's appeal failed and the cross-objection became academic.
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