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 80G - CIT(E) rejected the application u/s 80G - ITAT allowed the registration - CIT(E) had taken an unduly harsh and pedantic view of the matter and once it is not disputed that the stringent conditions u/s 12AA have been satisfied, the further action can only be taken at the end of the financial year to determine whether any donation etc or other the conditions of Section 80G have or have not been fulfilled.
Registration u/s 80G - CIT(E) rejected the application u/s 80G - ITAT allowed the registration - CIT(E) had taken an unduly harsh and pedantic view of the matter and once it is not disputed that the stringent conditions u/s 12AA have been satisfied, the further action can only be taken at the end of the financial year to determine whether any donation etc or other the conditions of Section 80G have or have not been fulfilled.
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