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 - Violation of provisions of Section 13(1 )(c) and 13(1)(d) - loans and advances to interested persons - We are of the considered view that the learned CIT appeal has been wrong interpretation of provisions of section 13(1)(d) and 13 (3) of the Act, qua the peculiar facts of the instant case. In our view, the appellant trust has violated the provisions of section 13(1)(c) and 13(1)(d) of the Act. Thus, the appellant is not entitled for exemption u/s 11 of the Act to that extent. - AT
Exemption u/s 11 - Violation of provisions of Section 13(1 )(c) and 13(1)(d) - loans and advances to interested persons - We are of the considered view that the learned CIT appeal has been wrong interpretation of provisions of section 13(1)(d) and 13 (3) of the Act, qua the peculiar facts of the instant case. In our view, the appellant trust has violated the provisions of section 13(1)(c) and 13(1)(d) of the Act. Thus, the appellant is not entitled for exemption u/s 11 of the Act to that extent. - AT
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