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 - Revenue Authorities have clearly observed that the assessee”s claim of relief to the poor or help to the poor is not correct since the income and expenditure statements filed by the assessee reflects substantial profits from the activities of the assessee and therefore the profit motto exists very much. It is a fact that granting of registration u/s. 12A does not confer any benefits of exemption of tax u/s. 10 or 11 of the Act which has to be independently decided. - the exemption U/s. 11 of the Act cannot be granted to the assessee - AT
Exemption u/s 11 - Revenue Authorities have clearly observed that the assessee”s claim of relief to the poor or help to the poor is not correct since the income and expenditure statements filed by the assessee reflects substantial profits from the activities of the assessee and therefore the profit motto exists very much. It is a fact that granting of registration u/s. 12A does not confer any benefits of exemption of tax u/s. 10 or 11 of the Act which has to be independently decided. - the exemption U/s. 11 of the Act cannot be granted to the assessee - AT
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