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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Rejecting registration u/s 12A(1)(ac)(iii) - name mismatch between the certificate of registration issued by the Charity Commissioner, Vadodara and the PAN database - The Tribunal agreed with the appellant's argument that the trust's objectives aimed at the general public utility and weren't solely for the benefit of a particular community. - The Appellate Tribunal found the appellant's explanation reasonable and directed the Commissioner to reevaluate the issue considering the detailed submissions provided by the appellant. They concluded that the name mismatch alone wasn't sufficient grounds for rejection. - In conclusion, the Tribunal allowed the appeal for statistical purposes, directing the Commissioner to reevaluate both the name mismatch and the nature of the trust's activities for eligibility under Section 12AA.
Rejecting registration u/s 12A(1)(ac)(iii) - name mismatch between the certificate of registration issued by the Charity Commissioner, Vadodara and the PAN database - The Tribunal agreed with the appellant's argument that the trust's objectives aimed at the general public utility and weren't solely for the benefit of a particular community. - The Appellate Tribunal found the appellant's explanation reasonable and directed the Commissioner to reevaluate the issue considering the detailed submissions provided by the appellant. They concluded that the name mismatch alone wasn't sufficient grounds for rejection. - In conclusion, the Tribunal allowed the appeal for statistical purposes, directing the Commissioner to reevaluate both the name mismatch and the nature of the trust's activities for eligibility under Section 12AA.
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