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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Registration u/s 12A and approval u/s 80G(5) earlier granted were withdrawn citing grounds like money laundering, loan default, TDS shortfall, delayed PF/ESIC payments, non-accounting of retirement benefits, and GST non-payment on rent. Tribunal set aside cancellation of 12A registration. On re-application, provisional 12AB and 80G(5) registrations were granted. Loan default, though contractual breach, isn't non-compliance of law governing assessee's activities. TDS shortfall/delay has remedy under IT Act. PF/ESIC delays entail disallowance under IT Act. Non-provisioning for retirement benefits isn't statutory violation. Assessee was exempt from GST registration. No dispute on charitable objects/activities. Impugned order set aside, directing grant of 12AB and 80G(5) registrations.
Registration u/s 12A and approval u/s 80G(5) earlier granted were withdrawn citing grounds like money laundering, loan default, TDS shortfall, delayed PF/ESIC payments, non-accounting of retirement benefits, and GST non-payment on rent. Tribunal set aside cancellation of 12A registration. On re-application, provisional 12AB and 80G(5) registrations were granted. Loan default, though contractual breach, isn't non-compliance of law governing assessee's activities. TDS shortfall/delay has remedy under IT Act. PF/ESIC delays entail disallowance under IT Act. Non-provisioning for retirement benefits isn't statutory violation. Assessee was exempt from GST registration. No dispute on charitable objects/activities. Impugned order set aside, directing grant of 12AB and 80G(5) registrations.
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