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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Regular Approval u/s 80G(5) - The High Court found that while the respondents had the authority to extend the time limit, there was no valid reason provided for the differential treatment between existing and new trusts regarding Section 80G approval. The court noted that the classification lacked a rational nexus with the object sought to be achieved, rendering it arbitrary and unconstitutional. - The court held that the petitioners did not have an inherent right to claim further extensions of time, even if an initial extension was granted by the respondents. The extension of time was considered an act of benevolence rather than a creation of vested rights on the part of the petitioners.
Regular Approval u/s 80G(5) - The High Court found that while the respondents had the authority to extend the time limit, there was no valid reason provided for the differential treatment between existing and new trusts regarding Section 80G approval. The court noted that the classification lacked a rational nexus with the object sought to be achieved, rendering it arbitrary and unconstitutional. - The court held that the petitioners did not have an inherent right to claim further extensions of time, even if an initial extension was granted by the respondents. The extension of time was considered an act of benevolence rather than a creation of vested rights on the part of the petitioners.
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