Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
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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