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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Cancellation of registration u/s 12AB(4) denied - trust's investments in mutual funds from accumulations and corpus donations, not borrowed funds - trust deed clause allowing settlor's accommodation became infructuous after settlor's death in 1965, not violating section 13(3) - investments in mutual funds to meet section 11(5) requirements - CIT(Exemption) cannot cancel registration merely based on trust deed covenants without examining actual activities - activities genuine and in accordance with objects - order set aside, appeal allowed.
Cancellation of registration u/s 12AB(4) denied - trust's investments in mutual funds from accumulations and corpus donations, not borrowed funds - trust deed clause allowing settlor's accommodation became infructuous after settlor's death in 1965, not violating section 13(3) - investments in mutual funds to meet section 11(5) requirements - CIT(Exemption) cannot cancel registration merely based on trust deed covenants without examining actual activities - activities genuine and in accordance with objects - order set aside, appeal allowed.
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