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 - when the objects of the Assessee are charitable in nature being solely for the purpose of education and all activities spring from and are to be read in conjunction with clause 2 (b) of the Deed of Trust and there is nothing brought on record by the CIT(E) to show the objects of the Assessee are not charitable or that its activities are not genuine then registration ought to have been granted
Registration u/s.12AA - when the objects of the Assessee are charitable in nature being solely for the purpose of education and all activities spring from and are to be read in conjunction with clause 2 (b) of the Deed of Trust and there is nothing brought on record by the CIT(E) to show the objects of the Assessee are not charitable or that its activities are not genuine then registration ought to have been granted
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