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 ITAT allowed the assessee's appeals on the following grounds: 1) Regarding exemption u/s 11 for charitable activity, the matter was referred to the AO to examine allowability in view of the SC decision in ACIT vs. Ahmedabad Urban Development Authority on computation of receipts from trade/business. 2) The write-off of non-recoverable amounts from terminated members was allowed as the security deposits were non-refundable and taken into the assessee's corpus, and the dues were already shown as income.
The ITAT allowed the assessee's appeals on the following grounds: 1) Regarding exemption u/s 11 for charitable activity, the matter was referred to the AO to examine allowability in view of the SC decision in ACIT vs. Ahmedabad Urban Development Authority on computation of receipts from trade/business. 2) The write-off of non-recoverable amounts from terminated members was allowed as the security deposits were non-refundable and taken into the assessee's corpus, and the dues were already shown as income.
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