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 trust was denied registration u/s 12AB by the CIT(E) on grounds that its activities were restricted to a particular religious community or caste ("Leva Patel"), invoking Section 13(1)(b). However, the ITAT held that since the trust existed prior to the Income-Tax Act, 1961, Section 13(1)(b) would not apply. The trust's property was purchased in 1946 and 1959, before the Act's commencement. Even if created for a particular community, registration cannot be denied to a pre-existing trust if it fulfills conditions u/s 12AB and Rule 17A. The ITAT directed the CIT(E) to grant registration, provided other conditions are met, treating the appeal as allowed for statistical purposes.
The trust was denied registration u/s 12AB by the CIT(E) on grounds that its activities were restricted to a particular religious community or caste ("Leva Patel"), invoking Section 13(1)(b). However, the ITAT held that since the trust existed prior to the Income-Tax Act, 1961, Section 13(1)(b) would not apply. The trust's property was purchased in 1946 and 1959, before the Act's commencement. Even if created for a particular community, registration cannot be denied to a pre-existing trust if it fulfills conditions u/s 12AB and Rule 17A. The ITAT directed the CIT(E) to grant registration, provided other conditions are met, treating the appeal as allowed for statistical purposes.
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