Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Denial of exemption u/s 10(23C)(vi) - CIT(E) observed the huge surplus which indicates that the activities are conducted with the motive of profit. - even if for any year the taxpayer is found to be existing solely for educational purposes and not for purposes of profit, the assessee still has to continuously satisfy this pivotal condition each and every year. - Since the assessee has been found to be not ‘existing’ solely for the purposes of education, denial of exemption u/s 10(23C)(vi) of the Act is upheld. - AT
Denial of exemption u/s 10(23C)(vi) - CIT(E) observed the huge surplus which indicates that the activities are conducted with the motive of profit. - even if for any year the taxpayer is found to be existing solely for educational purposes and not for purposes of profit, the assessee still has to continuously satisfy this pivotal condition each and every year. - Since the assessee has been found to be not ‘existing’ solely for the purposes of education, denial of exemption u/s 10(23C)(vi) of the Act is upheld. - AT
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