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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Rejection of Application for Final Approval u/s 80G(5)(iii) - The Tribunal observed that the CBDT Circular extending the date for final applications did not apply to institutions filing under Clause (iv) to First Proviso to section 80G(5) of the Act. It ruled that the appellant's application for final approval was within the limitation period and directed the CIT(Exemption) to grant provisional approval if the appellant met eligibility criteria. Additionally, the Tribunal clarified that if final approval was granted, the benefit of approval under section 80G of the Act would be deemed to continue without break.
Rejection of Application for Final Approval u/s 80G(5)(iii) - The Tribunal observed that the CBDT Circular extending the date for final applications did not apply to institutions filing under Clause (iv) to First Proviso to section 80G(5) of the Act. It ruled that the appellant's application for final approval was within the limitation period and directed the CIT(Exemption) to grant provisional approval if the appellant met eligibility criteria. Additionally, the Tribunal clarified that if final approval was granted, the benefit of approval under section 80G of the Act would be deemed to continue without break.
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