Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Exemption u/s 10(23C) (iv) - Charitable activity u/s 2(15) or not? - The petitioner, an institution promoting trade, sought exemption under Section 10(23C)(iv) of the Income Tax Act. The Revenue rejected the claim, citing the proviso to Section 2(15) of the Act. The petitioner challenged this decision, relying on a subsequent ITAT judgment. The court upheld the retrospective application of judicial decisions and emphasized the binding nature of appellate authority's orders on revenue officers. It quashed the impugned order and remanded the matter for reconsideration in light of the ITAT's decision.
Exemption u/s 10(23C) (iv) - Charitable activity u/s 2(15) or not? - The petitioner, an institution promoting trade, sought exemption under Section 10(23C)(iv) of the Income Tax Act. The Revenue rejected the claim, citing the proviso to Section 2(15) of the Act. The petitioner challenged this decision, relying on a subsequent ITAT judgment. The court upheld the retrospective application of judicial decisions and emphasized the binding nature of appellate authority's orders on revenue officers. It quashed the impugned order and remanded the matter for reconsideration in light of the ITAT's decision.
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