Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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