Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
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Charitable purpose is not defeated where sponsorship receipts from a women's marathon have a real and proximate nexus with objects of women's health, fitness, awareness and empowerment. The proviso to section 2(15) requires proof that the recipient's activity intrinsically operates as trade, commerce or business; sponsors' advertising treatment, receipt magnitude or surplus alone is insufficient. The 20% receipts formulation did not apply for the relevant assessment year, and exceeding the applicable monetary threshold could not replace that proof. Consequently, section 13(8) could not deny exemption under sections 11 and 12. Form No. 10B furnished during assessment cured an erroneous original exemption form where audit was completed before return filing and eligibility was examined on merits; the lapse was procedural.
Charitable purpose is not defeated where sponsorship receipts from a women's marathon have a real and proximate nexus with objects of women's health, fitness, awareness and empowerment. The proviso to section 2(15) requires proof that the recipient's activity intrinsically operates as trade, commerce or business; sponsors' advertising treatment, receipt magnitude or surplus alone is insufficient. The 20% receipts formulation did not apply for the relevant assessment year, and exceeding the applicable monetary threshold could not replace that proof. Consequently, section 13(8) could not deny exemption under sections 11 and 12. Form No. 10B furnished during assessment cured an erroneous original exemption form where audit was completed before return filing and eligibility was examined on merits; the lapse was procedural.
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