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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Section 11 exemption - Violation of Section 13(1)(d) regarding excess payment to sister trust disallowed. Honorarium paid to Ms. Meenakshi Sundaraja allowed based on Memorandum of Association and Tribunal's earlier decision. Payment of loan to M/s. Ganapathy Educational Trust (GET) for construction of college building, a sister concern with similar objects, allowed as it does not violate Section 13(1)(c). Assessee provided details of loan repayment to GET and payments made to contractors as directed by High Court. Payments made as loan to other charitable trusts do not violate Section 13(1)(c).
Section 11 exemption - Violation of Section 13(1)(d) regarding excess payment to sister trust disallowed. Honorarium paid to Ms. Meenakshi Sundaraja allowed based on Memorandum of Association and Tribunal's earlier decision. Payment of loan to M/s. Ganapathy Educational Trust (GET) for construction of college building, a sister concern with similar objects, allowed as it does not violate Section 13(1)(c). Assessee provided details of loan repayment to GET and payments made to contractors as directed by High Court. Payments made as loan to other charitable trusts do not violate Section 13(1)(c).
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