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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Rejection of Revision application u/s 264 - Exemption u/s 11 denied to assessee - benefits denied merely on the ground that the donor has deducted TDS u/s 194C and 194J while allocating requisite grants to the assessee - scope of principle of consistency in taxation matters - The High Court held that, the deduction of TDS under specific sections was deemed an insufficient basis to deny exemptions under Sections 11 and 12. The court underscored that such deductions, possibly made under a misconception by the donors, should not adversely affect the Foundation's eligibility for exemptions. - Benefit of exemption allowed.
Rejection of Revision application u/s 264 - Exemption u/s 11 denied to assessee - benefits denied merely on the ground that the donor has deducted TDS u/s 194C and 194J while allocating requisite grants to the assessee - scope of principle of consistency in taxation matters - The High Court held that, the deduction of TDS under specific sections was deemed an insufficient basis to deny exemptions under Sections 11 and 12. The court underscored that such deductions, possibly made under a misconception by the donors, should not adversely affect the Foundation's eligibility for exemptions. - Benefit of exemption allowed.
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