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 80G(5)(vi) - charitable activities and utilization of funds - deduction from total income on donations to be made available to donors based on such registration - infirmity in submission of income-tax return and non-submission of Form-10B - donations utilized for construction of Public Library. Held that there was no specific finding that donations/funds received were utilized for profit, personal gains, or other purposes. Use of donations/funds by renowned Society/Trust already working for charitable purposes should not be discarded from seeking exemption merely on technicalities like non-production of receipts/entries. No specific finding that the Society failed to meet its aims and objects. Registration/exemption u/s 80G granted from time to time, except for the period in question. Society continuously enjoyed registration u/s 12AA and comes within the definition of charitable Society/Trust/Establishment under the Income-tax Act, 1961. Construction of Public Library would form part of charitable function. Orders of CIT quashed/set aside and directed to reconsider application and grant renewal of registration u/s 80G(5)(vi).
Registration u/s 80G(5)(vi) - charitable activities and utilization of funds - deduction from total income on donations to be made available to donors based on such registration - infirmity in submission of income-tax return and non-submission of Form-10B - donations utilized for construction of Public Library. Held that there was no specific finding that donations/funds received were utilized for profit, personal gains, or other purposes. Use of donations/funds by renowned Society/Trust already working for charitable purposes should not be discarded from seeking exemption merely on technicalities like non-production of receipts/entries. No specific finding that the Society failed to meet its aims and objects. Registration/exemption u/s 80G granted from time to time, except for the period in question. Society continuously enjoyed registration u/s 12AA and comes within the definition of charitable Society/Trust/Establishment under the Income-tax Act, 1961. Construction of Public Library would form part of charitable function. Orders of CIT quashed/set aside and directed to reconsider application and grant renewal of registration u/s 80G(5)(vi).
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