Charitable sports promotion: sponsorship receipts alone did not defeat registration where funds supported tournaments and player development activitie...
Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as busi...
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require...
Transfer-pricing adjustments must reflect functional comparability, working-capital effects, and avoid duplicating interest on associated-enterprise r...
Statutory accumulation of 15 per cent of charitable income under section 11(1)(a) is distinct from further accumulation under section 11(2). Where charitable eligibility and application of income to charitable objects are satisfied, the statutory retention remains available. Accumulation beyond that limit may be claimed where Form No. 10 is furnished by the extended due date for filing the return, rather than only by the original due date. Charitable exemption should not be denied solely because Form No. 10BB was electronically furnished late if the audit report was available before return processing and substantive exemption conditions were met.
Statutory accumulation of 15 per cent of charitable income under section 11(1)(a) is distinct from further accumulation under section 11(2). Where charitable eligibility and application of income to charitable objects are satisfied, the statutory retention remains available. Accumulation beyond that limit may be claimed where Form No. 10 is furnished by the extended due date for filing the return, rather than only by the original due date. Charitable exemption should not be denied solely because Form No. 10BB was electronically furnished late if the audit report was available before return processing and substantive exemption conditions were met.
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