Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
ITAT ruled on income computation under Section 11(1) for a charitable trust manufacturing artificial limbs. Revenue generated from manufacturing activities qualifies as eligible income for accumulation purposes, considering the trust's primary objective of serving disabled persons with affordable prosthetics. The Tribunal directed 15% accumulation under Section 11(1)(a) to be calculated on gross receipts. However, loans received under ADIP and ADIP-SSA schemes were excluded from income computation under Section 11(1), though they can be considered as application of income during utilization year. The trust exceeded the 85% income utilization requirement during the assessment year. Ground nos. 2 and 3 were allowed, while ground no. 4 was dismissed.
ITAT ruled on income computation under Section 11(1) for a charitable trust manufacturing artificial limbs. Revenue generated from manufacturing activities qualifies as eligible income for accumulation purposes, considering the trust's primary objective of serving disabled persons with affordable prosthetics. The Tribunal directed 15% accumulation under Section 11(1)(a) to be calculated on gross receipts. However, loans received under ADIP and ADIP-SSA schemes were excluded from income computation under Section 11(1), though they can be considered as application of income during utilization year. The trust exceeded the 85% income utilization requirement during the assessment year. Ground nos. 2 and 3 were allowed, while ground no. 4 was dismissed.
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