Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Denial of exemption u/s 11 & 12 - Assessment of trust - Taxation at Maximum Marginal Rate (MMR) - charging the assessee as per the provisions of section 164(1) or 164(2) - The ITAT concluded that taxing the trust at MMR was incorrect. The tribunal recognized the trust's registration under the Indian Stamp Act and noted its primary activity was the maintenance of a Jain temple, hence benefiting the public at large. The ITAT ruled that since the trust's registration under section 12A was effective from 2022, previous years should be taxed under the provisions applicable to trusts with indeterminate beneficiaries, i.e., as an AOP or individual, which allows for a more favorable tax treatment including basic exemptions.
Denial of exemption u/s 11 & 12 - Assessment of trust - Taxation at Maximum Marginal Rate (MMR) - charging the assessee as per the provisions of section 164(1) or 164(2) - The ITAT concluded that taxing the trust at MMR was incorrect. The tribunal recognized the trust's registration under the Indian Stamp Act and noted its primary activity was the maintenance of a Jain temple, hence benefiting the public at large. The ITAT ruled that since the trust's registration under section 12A was effective from 2022, previous years should be taxed under the provisions applicable to trusts with indeterminate beneficiaries, i.e., as an AOP or individual, which allows for a more favorable tax treatment including basic exemptions.
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