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...
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...
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Registration u/s 12AA - there is no provision for any type of free or concessional education to the poor and needy students rather the clauses in the Agreement makes it binding on the trust not to offer any discounts or concessions, trust cannot even grant credit to the needy students in case of financial crisis and the interest is chrgeble on day to day basis - Such type of activity cannot be considered as charitable activity - no registration
Registration u/s 12AA - there is no provision for any type of free or concessional education to the poor and needy students rather the clauses in the Agreement makes it binding on the trust not to offer any discounts or concessions, trust cannot even grant credit to the needy students in case of financial crisis and the interest is chrgeble on day to day basis - Such type of activity cannot be considered as charitable activity - no registration
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