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 - assessee has not shown that the amount kept in fixed deposits have been allocated to or earmarked for a charitable purpose - Section 11(1A) is concerned with the capital gains arising on sale of a capital asset and its reinvestment for the purpose of availing exemption, i.e., conversion of one capital asset into another capital asset. Sec. 11(5) prescribes mode of making investments. In our view, those provisions will not support the claim of the assessee, since the deduction has been claimed u/s 11(1)(a) of the Act, as per which the income has to be applied for charitable purposes. - AT
Exemption u/s 11 - assessee has not shown that the amount kept in fixed deposits have been allocated to or earmarked for a charitable purpose - Section 11(1A) is concerned with the capital gains arising on sale of a capital asset and its reinvestment for the purpose of availing exemption, i.e., conversion of one capital asset into another capital asset. Sec. 11(5) prescribes mode of making investments. In our view, those provisions will not support the claim of the assessee, since the deduction has been claimed u/s 11(1)(a) of the Act, as per which the income has to be applied for charitable purposes. - AT
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