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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Revision u/s 263 - assessment of trust - donations given out of accumulated funds u/s. 11(2) of the Act of earlier previous years - The Tribunal noted the argument that the funds were disbursed only after ensuring they were used for construction purposes, aligning with the trust's objectives. - Upon careful consideration of the provisions of section 11(2) and section 11(3)(d) of the Act, the Tribunal concurred with the Ld. CIT (Exemption)'s finding that the donations made by the assessee from accumulated funds fell outside the permissible scope and were therefore taxable as income. The Tribunal upheld the decision that the assessment order lacked proper inquiry and verification by the AO, justifying the exercise of jurisdiction under section 263 of the Act.
Revision u/s 263 - assessment of trust - donations given out of accumulated funds u/s. 11(2) of the Act of earlier previous years - The Tribunal noted the argument that the funds were disbursed only after ensuring they were used for construction purposes, aligning with the trust's objectives. - Upon careful consideration of the provisions of section 11(2) and section 11(3)(d) of the Act, the Tribunal concurred with the Ld. CIT (Exemption)'s finding that the donations made by the assessee from accumulated funds fell outside the permissible scope and were therefore taxable as income. The Tribunal upheld the decision that the assessment order lacked proper inquiry and verification by the AO, justifying the exercise of jurisdiction under section 263 of the Act.
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