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 upheld the denial of registration u/s 12AB to the Trust, as its objects were exclusively for the Jain Community, violating Section 13(1)(b) read with the explanation to Section 12AB(4). Registration u/ss 12A and 12AA is a prerequisite for claiming exemption u/ss 11 and 12. Section 13(1)(b) prohibits exemption to trusts established after the Act's commencement for the benefit of a particular religious community or caste. The CIT(E)'s order denying registration, being within the amended law's provisions, was upheld.
The ITAT upheld the denial of registration u/s 12AB to the Trust, as its objects were exclusively for the Jain Community, violating Section 13(1)(b) read with the explanation to Section 12AB(4). Registration u/ss 12A and 12AA is a prerequisite for claiming exemption u/ss 11 and 12. Section 13(1)(b) prohibits exemption to trusts established after the Act's commencement for the benefit of a particular religious community or caste. The CIT(E)'s order denying registration, being within the amended law's provisions, was upheld.
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