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 - status of the assessee trust - The assessee trust is irrevocable trust which is duly registered under section 12A and thus, eligible for exemption u/s section 11 and 12 of the Act and during the period relevant to impugned assessment year, there was no violation of section 11(5) as well as section 13(1)(c)(ii) of the Act and thus, the exemption under section 11 and 12 has been rightly claimed by the assessee trust- AT
Exemption u/s 11 - status of the assessee trust - The assessee trust is irrevocable trust which is duly registered under section 12A and thus, eligible for exemption u/s section 11 and 12 of the Act and during the period relevant to impugned assessment year, there was no violation of section 11(5) as well as section 13(1)(c)(ii) of the Act and thus, the exemption under section 11 and 12 has been rightly claimed by the assessee trust- AT
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