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...
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Subsisting registration under section 12AB remains legally effective until lawfully withdrawn or cancelled, even if the trust selected an incorrect sub-clause in an earlier registration application. Renewal falls under section 12A(1)(ac)(ii) where an existing section 12AB registration is due to expire. Absence of registration under the earlier section 12A/12AA regime does not justify rejection where no adverse finding concerns the objects, genuineness of activities, or registration conditions. Renewal rejection on that basis was set aside and registration was directed for the applicable period.
Subsisting registration under section 12AB remains legally effective until lawfully withdrawn or cancelled, even if the trust selected an incorrect sub-clause in an earlier registration application. Renewal falls under section 12A(1)(ac)(ii) where an existing section 12AB registration is due to expire. Absence of registration under the earlier section 12A/12AA regime does not justify rejection where no adverse finding concerns the objects, genuineness of activities, or registration conditions. Renewal rejection on that basis was set aside and registration was directed for the applicable period.
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