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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Charitable registration requires examination of both the stated charitable objects and prima facie evidence that genuine charitable activities are being carried on. Educational objects in a trust deed are insufficient where the trust does not itself establish, manage, or impart education through a recognised educational institution. Leasing school and hostel premises to another educational entity and earning lease rent does not, by itself, demonstrate that the lessor trust conducts educational charitable activity. In the absence of evidence that rental income was applied to the trust's own charitable purposes, the registration application was rejected.
Charitable registration requires examination of both the stated charitable objects and prima facie evidence that genuine charitable activities are being carried on. Educational objects in a trust deed are insufficient where the trust does not itself establish, manage, or impart education through a recognised educational institution. Leasing school and hostel premises to another educational entity and earning lease rent does not, by itself, demonstrate that the lessor trust conducts educational charitable activity. In the absence of evidence that rental income was applied to the trust's own charitable purposes, the registration application was rejected.
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