Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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Interest on bank fixed deposits held in a trust's name constitutes the trust's income, even where the funds are intended for Self-Help Groups. Corpus exemption requires a specific written direction from the donor; correspondence allowing distribution of refunded funds did not direct that deposit interest form part of the corpus. A later obligation to allocate funds to Self-Help Groups is application of income, not diversion at source. The trust cannot claim tax deducted at source credit while excluding the interest from revenue receipts. The interest was taxable as revenue income, and its addition was affirmed.
Interest on bank fixed deposits held in a trust's name constitutes the trust's income, even where the funds are intended for Self-Help Groups. Corpus exemption requires a specific written direction from the donor; correspondence allowing distribution of refunded funds did not direct that deposit interest form part of the corpus. A later obligation to allocate funds to Self-Help Groups is application of income, not diversion at source. The trust cannot claim tax deducted at source credit while excluding the interest from revenue receipts. The interest was taxable as revenue income, and its addition was affirmed.
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