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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Exemption u/s 11 and 12 - religious activities - violation of Section 13(1)(c) - the activities undertaken by the assessee can be included in the broad conspectus of religious activities and in the context of Hindu Religion, such activities cannot be confined to activities incidental to a place of worship like a temple. - There is no evidence on record to construe that the GurudevJi “has derived any personal benefit” which would justify the Revenue to invoke the provisions of Section 13(1)(c)(ii) to deny assessee the benefit of the expenditure.
Exemption u/s 11 and 12 - religious activities - violation of Section 13(1)(c) - the activities undertaken by the assessee can be included in the broad conspectus of religious activities and in the context of Hindu Religion, such activities cannot be confined to activities incidental to a place of worship like a temple. - There is no evidence on record to construe that the GurudevJi “has derived any personal benefit” which would justify the Revenue to invoke the provisions of Section 13(1)(c)(ii) to deny assessee the benefit of the expenditure.
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