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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Rejection of certification u/s 80G - Charitable object u/s 2(15) - Charitable purpose - We note that just because in the objects of the trust, it is mentioned that assessee-trust may celebrate Ganesh Utsav, Janmastami, Navaratri, Diwali, New Year, Holi does not mean that it is engaged in religious activities. These are the normal functions in the society and everybody celebrate them, hence it does not mean that the assessee-trust has established only to celebrate Ganesh, Janmastami, Jalaram Jayanti, Navratri, Diwali, New Year and Holi. - AT
Rejection of certification u/s 80G - Charitable object u/s 2(15) - Charitable purpose - We note that just because in the objects of the trust, it is mentioned that assessee-trust may celebrate Ganesh Utsav, Janmastami, Navaratri, Diwali, New Year, Holi does not mean that it is engaged in religious activities. These are the normal functions in the society and everybody celebrate them, hence it does not mean that the assessee-trust has established only to celebrate Ganesh, Janmastami, Jalaram Jayanti, Navratri, Diwali, New Year and Holi. - AT
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