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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The Notification approves 'Amul Research and Development Association' for research in 'Scientific Research' under the provisions of section 35 of the Income-tax Act, 1961. It is mentioned that the approval is granted with retrospective effect from Assessment Years 2008-09 to 2021-22. This decision is in accordance with Rules 5C and 5D of the Income-tax Rules, 1962. The Notification also includes an explanatory memorandum, citing the Gujarat High Court orders in the case of M/s Amul Research and Development Association vs. CBDT, which necessitated the issuance of this Notification. It is further certified that no adverse effects are imposed on any individual by granting retrospective effect to this Notification.
The Notification approves 'Amul Research and Development Association' for research in 'Scientific Research' under the provisions of section 35 of the Income-tax Act, 1961. It is mentioned that the approval is granted with retrospective effect from Assessment Years 2008-09 to 2021-22. This decision is in accordance with Rules 5C and 5D of the Income-tax Rules, 1962. The Notification also includes an explanatory memorandum, citing the Gujarat High Court orders in the case of M/s Amul Research and Development Association vs. CBDT, which necessitated the issuance of this Notification. It is further certified that no adverse effects are imposed on any individual by granting retrospective effect to this Notification.
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