Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Exemption u/s 11 - Charitable activity u/s 2(15) - Commercial activity - Citing past decisions favorable to the trust under similar assessments, the Tribunal reiterated that activities generating income do not automatically disqualify an entity from being charitable if the primary purpose is charitable and the commercial activities are incidental. It was highlighted that the trust's income was indeed applied towards its stated charitable purposes, fulfilling the criteria for exemption under Section 11.
Exemption u/s 11 - Charitable activity u/s 2(15) - Commercial activity - Citing past decisions favorable to the trust under similar assessments, the Tribunal reiterated that activities generating income do not automatically disqualify an entity from being charitable if the primary purpose is charitable and the commercial activities are incidental. It was highlighted that the trust's income was indeed applied towards its stated charitable purposes, fulfilling the criteria for exemption under Section 11.
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