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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Power of CIT to cancel or withdraw registration invoking Section 12AA(3) - The High Court dismissed the appeals filed by the Revenue and upheld the ITAT's orders restoring the registrations of the educational trusts. The court held that the Commissioner did not have the authority to cancel registrations granted u/s 12A before the amendment in 2010. The court emphasized that generating a surplus in educational activities does not imply a profit motive if the surplus is used for charitable purposes.
Power of CIT to cancel or withdraw registration invoking Section 12AA(3) - The High Court dismissed the appeals filed by the Revenue and upheld the ITAT's orders restoring the registrations of the educational trusts. The court held that the Commissioner did not have the authority to cancel registrations granted u/s 12A before the amendment in 2010. The court emphasized that generating a surplus in educational activities does not imply a profit motive if the surplus is used for charitable purposes.
Note: It is a system-generated summary and is for quick reference only.