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 - undue benefit to specified persons - denial of exemption to extent of rent paid by the assessee to one of its trustees holding the same to be on higher side as compared to market rate by invoking the provisions of section 13 (1)(c) - when the entire land was required by the assessee society for its objective of imparting education, there cannot be said that any benefit had been given to the lessor by retaining its land on lease instead of buying it off - Denial of exemption u/ s 11 rejected - AT
Exemption u/s 11 - undue benefit to specified persons - denial of exemption to extent of rent paid by the assessee to one of its trustees holding the same to be on higher side as compared to market rate by invoking the provisions of section 13 (1)(c) - when the entire land was required by the assessee society for its objective of imparting education, there cannot be said that any benefit had been given to the lessor by retaining its land on lease instead of buying it off - Denial of exemption u/ s 11 rejected - AT
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