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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Benefit of the provisions of Section 10 (23C)(iiiab) - There is a sweeping difference in according the any assessee to the provisions of Section 12AA and Section 10(23C)(iiiab). The conditions and requirements of registration under Section 12 AA and the conditions and prerequisites for the claiming the benefit u/ s 10(23C)(iiiab) differs. We also find that the assessee has been granted registration u/s 12 AA from the provisions of the Act and on going through the various judgments, we hereby hold that the assessee is not entitled to the benefit of Section 10(23C)(iiiab). - AT
Benefit of the provisions of Section 10 (23C)(iiiab) - There is a sweeping difference in according the any assessee to the provisions of Section 12AA and Section 10(23C)(iiiab). The conditions and requirements of registration under Section 12 AA and the conditions and prerequisites for the claiming the benefit u/ s 10(23C)(iiiab) differs. We also find that the assessee has been granted registration u/s 12 AA from the provisions of the Act and on going through the various judgments, we hereby hold that the assessee is not entitled to the benefit of Section 10(23C)(iiiab). - AT
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