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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Denial of Approval u/s 80G - The Assessee's argument that donations were required for non-recurring expenses related to construction was not supported by evidence. Additionally, no expenditures in the Income & Expenditure account were found to correspond with the charitable claims made by the Assessee. - Considering these factors, the Ld. CIT(E) concluded that the Assessee's purpose for seeking donations did not align with the objectives of section 80G. As the Assessee failed to provide any other compelling rationale for approval, the request was denied. - Tribunal upheld the Order of CIT(E).
Denial of Approval u/s 80G - The Assessee's argument that donations were required for non-recurring expenses related to construction was not supported by evidence. Additionally, no expenditures in the Income & Expenditure account were found to correspond with the charitable claims made by the Assessee. - Considering these factors, the Ld. CIT(E) concluded that the Assessee's purpose for seeking donations did not align with the objectives of section 80G. As the Assessee failed to provide any other compelling rationale for approval, the request was denied. - Tribunal upheld the Order of CIT(E).
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