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 appellant Trust's application for registration u/s 12A was rejected by the Commissioner of Income Tax (Exemptions) on the grounds that its activities were not aligned with the objects mentioned in its Memorandum of Association, and the genuineness of its activities could not be conclusively proven. The Trust was directed to provide desired details to establish the charitable nature of its objectives and the genuineness of its activities as per the Memorandum of Association. The Commissioner of Income Tax (Exemptions) observed that the Trust's source of funds involved a transfer entry on the same day, which was transferred back in the same manner to the same party, raising concerns about the genuineness of its activities for charitable purposes. In the interest of natural justice, the Income Tax Appellate Tribunal set aside the Commissioner of Income Tax (Exemptions)'s order and remanded the matter back, directing the Commissioner to pass a de novo order after providing a reasonable opportunity to the assessee to prove its claim. The appeal was allowed for statistical purposes.
The appellant Trust's application for registration u/s 12A was rejected by the Commissioner of Income Tax (Exemptions) on the grounds that its activities were not aligned with the objects mentioned in its Memorandum of Association, and the genuineness of its activities could not be conclusively proven. The Trust was directed to provide desired details to establish the charitable nature of its objectives and the genuineness of its activities as per the Memorandum of Association. The Commissioner of Income Tax (Exemptions) observed that the Trust's source of funds involved a transfer entry on the same day, which was transferred back in the same manner to the same party, raising concerns about the genuineness of its activities for charitable purposes. In the interest of natural justice, the Income Tax Appellate Tribunal set aside the Commissioner of Income Tax (Exemptions)'s order and remanded the matter back, directing the Commissioner to pass a de novo order after providing a reasonable opportunity to the assessee to prove its claim. The appeal was allowed for statistical purposes.
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