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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Educational trust's appeal against denial of exemption u/s 10(23C)(iiiad) was allowed by ITAT. The trust, established in 1962, exclusively provides government-recognized educational services with annual income below Rs. 5 crores. ITAT found the institution satisfied all statutory requirements as it existed solely for educational purposes since inception, with no competing activities. The tribunal determined the trust's educational focus was uncontested by revenue authorities and met the criteria for tax exemption. The demand notice was nullified as the trust qualified for relief under 10(23C)(iiiad). ITAT directed revenue authorities to process exemption and withdraw assessment proceedings.
Educational trust's appeal against denial of exemption u/s 10(23C)(iiiad) was allowed by ITAT. The trust, established in 1962, exclusively provides government-recognized educational services with annual income below Rs. 5 crores. ITAT found the institution satisfied all statutory requirements as it existed solely for educational purposes since inception, with no competing activities. The tribunal determined the trust's educational focus was uncontested by revenue authorities and met the criteria for tax exemption. The demand notice was nullified as the trust qualified for relief under 10(23C)(iiiad). ITAT directed revenue authorities to process exemption and withdraw assessment proceedings.
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