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...
The ITAT Bangalore considered whether an organization engaged in microfinancing activities qualified for exemption u/s 11 as a charitable entity or if its activities were commercial in nature. The tribunal emphasized that if an organization's primary activity is trade or business, it must not have a dominant profit motive and should not use charity as a cover for commercial activities. The tribunal noted that charging exorbitant interest rates akin to commercial banks indicated a profit-driven motive, making it ineligible for exemption. The organization's activities did not align with benefiting low-income groups as required for charitable status. The tribunal ruled in favor of the revenue authority, denying the organization's claim for exemption u/s 11.
The ITAT Bangalore considered whether an organization engaged in microfinancing activities qualified for exemption u/s 11 as a charitable entity or if its activities were commercial in nature. The tribunal emphasized that if an organization's primary activity is trade or business, it must not have a dominant profit motive and should not use charity as a cover for commercial activities. The tribunal noted that charging exorbitant interest rates akin to commercial banks indicated a profit-driven motive, making it ineligible for exemption. The organization's activities did not align with benefiting low-income groups as required for charitable status. The tribunal ruled in favor of the revenue authority, denying the organization's claim for exemption u/s 11.
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