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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The Appellate Tribunal considered the issue of registration u/s 80G(5)(iii). The provisional registration was questioned due to a delay in applying for regular registration. The Tribunal found the activities of the Bar Association to be charitable and consistent, despite the delay in applying. The Tribunal criticized the incorrect procedure of granting provisional registration and subsequent denial of regular registration. The Tribunal deemed the application for regular registration to be within the extended time limit set by the Board. The Tribunal directed the Exemption Commissioner to grant registration u/s 80G(5)(iii) to the assessee, as the activities remained unchanged. The earlier registration u/s 80G(5)(vi) was cancelled due to a change in law. The Tribunal allowed the appeal of the assessee.
The Appellate Tribunal considered the issue of registration u/s 80G(5)(iii). The provisional registration was questioned due to a delay in applying for regular registration. The Tribunal found the activities of the Bar Association to be charitable and consistent, despite the delay in applying. The Tribunal criticized the incorrect procedure of granting provisional registration and subsequent denial of regular registration. The Tribunal deemed the application for regular registration to be within the extended time limit set by the Board. The Tribunal directed the Exemption Commissioner to grant registration u/s 80G(5)(iii) to the assessee, as the activities remained unchanged. The earlier registration u/s 80G(5)(vi) was cancelled due to a change in law. The Tribunal allowed the appeal of the assessee.
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