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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Grant of approval u/s 80G (5) - Donations - scope of amended provisions of section 2(15) - The amended definition of section 2(15) states that in course of achieving objects of general public utility, the concerned trust, society or other such organization carry on trade, commerce or business or provide service and relation thereto for consideration provided that firstly the activities of trade, commerce, or business, or connected to achievement of its object of general public utility in relation thereto, does not exceed the quantified limits that is 20% of total receipts of the previous year. - Assessee directed to file fresh application for de-nove consideration by PCIT - AT
Grant of approval u/s 80G (5) - Donations - scope of amended provisions of section 2(15) - The amended definition of section 2(15) states that in course of achieving objects of general public utility, the concerned trust, society or other such organization carry on trade, commerce or business or provide service and relation thereto for consideration provided that firstly the activities of trade, commerce, or business, or connected to achievement of its object of general public utility in relation thereto, does not exceed the quantified limits that is 20% of total receipts of the previous year. - Assessee directed to file fresh application for de-nove consideration by PCIT - AT
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