Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
The CBDT has issued a circular which addresses conditions under which income from specific funds, trusts, institutions, universities, educational, or medical institutions can enjoy tax exemption under the Income-tax Act, 1961. It outlines that at least 85% of such entities' income must be used for charitable or religious purposes, directly or through donations to similar entities. Amendments by the Finance Act 2023 clarify that only 85% of eligible donations are considered for charitable or religious application, with the balance 15% not needing to be invested per section 11(5) for exemption eligibility.
The CBDT has issued a circular which addresses conditions under which income from specific funds, trusts, institutions, universities, educational, or medical institutions can enjoy tax exemption under the Income-tax Act, 1961. It outlines that at least 85% of such entities' income must be used for charitable or religious purposes, directly or through donations to similar entities. Amendments by the Finance Act 2023 clarify that only 85% of eligible donations are considered for charitable or religious application, with the balance 15% not needing to be invested per section 11(5) for exemption eligibility.
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