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 Income Tax Bill, 2025 introduces enhanced regulatory framework for commercial activities by non-profit organizations through Clause 346, building upon Section 2(15) of Income-tax Act, 1961. The provision maintains the 20% revenue threshold for commercial activities while introducing stricter compliance requirements. Key modifications include mandatory separate accounting for commercial ventures, explicit definition of activities directly related to charitable objectives, and enhanced monitoring mechanisms. The framework applies specifically to registered non-profits, compared to the broader application under the 1961 Act. The provision aims to balance legitimate revenue generation with charitable purposes while preventing misuse through commercial operations. This structured approach provides clearer operational guidelines for organizations and regulators, though implementation challenges remain regarding activity classification and compliance monitoring.
The Income Tax Bill, 2025 introduces enhanced regulatory framework for commercial activities by non-profit organizations through Clause 346, building upon Section 2(15) of Income-tax Act, 1961. The provision maintains the 20% revenue threshold for commercial activities while introducing stricter compliance requirements. Key modifications include mandatory separate accounting for commercial ventures, explicit definition of activities directly related to charitable objectives, and enhanced monitoring mechanisms. The framework applies specifically to registered non-profits, compared to the broader application under the 1961 Act. The provision aims to balance legitimate revenue generation with charitable purposes while preventing misuse through commercial operations. This structured approach provides clearer operational guidelines for organizations and regulators, though implementation challenges remain regarding activity classification and compliance monitoring.
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