Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Exemption u/s 11 and 12 - charitable activity u/s 2(15) - total receipts from trade, commerce or business/service exceeded 20% of total receipts - The ITAT, referencing the Supreme Court's judgment in the case of CIT vs. AUDA & others, held that the assessee's activities were in the nature of advancement of general public utility and were not commercial. Thus, it was eligible for exemption under sections 11 & 12 of the Act. The Tribunal rejected the Revenue's appeal, emphasizing that activities carried out by statutory bodies for public utility, even if they generate income, do not constitute commercial activities if they are within the bounds of the specified statutory framework and aim.
Exemption u/s 11 and 12 - charitable activity u/s 2(15) - total receipts from trade, commerce or business/service exceeded 20% of total receipts - The ITAT, referencing the Supreme Court's judgment in the case of CIT vs. AUDA & others, held that the assessee's activities were in the nature of advancement of general public utility and were not commercial. Thus, it was eligible for exemption under sections 11 & 12 of the Act. The Tribunal rejected the Revenue's appeal, emphasizing that activities carried out by statutory bodies for public utility, even if they generate income, do not constitute commercial activities if they are within the bounds of the specified statutory framework and aim.
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