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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ITAT recalled its earlier order upon finding a mistake apparent on record regarding trust registration status under section 12A. Initially, ITAT had set aside CIT(E)'s rejection of trust's application for final registration, directing reconsideration. However, pursuant to CBDT Circular No. 11/2022, it was clarified that Form 10AC registrations issued during FY 2021-22, despite being labeled "provisional," were to be treated as final registrations. The trust already possessed valid final registration until AY 2026-27, making subsequent application unnecessary. ITAT acknowledged the error stemming from Form 10AC's incorrect provisional designation and recalled its previous order, effectively upholding CIT(E)'s original rejection of the redundant registration application.
ITAT recalled its earlier order upon finding a mistake apparent on record regarding trust registration status under section 12A. Initially, ITAT had set aside CIT(E)'s rejection of trust's application for final registration, directing reconsideration. However, pursuant to CBDT Circular No. 11/2022, it was clarified that Form 10AC registrations issued during FY 2021-22, despite being labeled "provisional," were to be treated as final registrations. The trust already possessed valid final registration until AY 2026-27, making subsequent application unnecessary. ITAT acknowledged the error stemming from Form 10AC's incorrect provisional designation and recalled its previous order, effectively upholding CIT(E)'s original rejection of the redundant registration application.
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