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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Exemption u/s 11 - benefit denied on delay in filling the audit report - The Appellate Tribunal acknowledged the delay in filing Form 10B but noted that the issue of denial of exemption solely on the grounds of this delay has been addressed in various judicial precedents. It cited the Gujarat High Court's decision in Sarvodaya Charitable Trust vs. ITO(E) and similar rulings by other benches. These rulings established that if a trust substantially satisfies the conditions for exemption under section 11, denial of exemption solely on the basis of a procedural delay is unjustified.
Exemption u/s 11 - benefit denied on delay in filling the audit report - The Appellate Tribunal acknowledged the delay in filing Form 10B but noted that the issue of denial of exemption solely on the grounds of this delay has been addressed in various judicial precedents. It cited the Gujarat High Court's decision in Sarvodaya Charitable Trust vs. ITO(E) and similar rulings by other benches. These rulings established that if a trust substantially satisfies the conditions for exemption under section 11, denial of exemption solely on the basis of a procedural delay is unjustified.
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