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 overturned denial of registration under s.12AB despite trust's non-registration under Rajasthan Public Trust Act 1959. Tribunal held RPT Act registration not mandatory for tax registration as statutes operate independently without overriding effect. On FCRA compliance, matter remanded to CIT(E) with direction for trust to amend deed requiring prior MHA approval for foreign contributions. Regarding genuineness of activities, ITAT found CIT(E)'s observations self-contradictory and unsupported, noting trust had purchased land for hostel construction as new entity. Following precedent, mere lack of extensive operations at initial stage cannot justify registration denial. Registration granted subject to FCRA compliance amendment.
ITAT overturned denial of registration under s.12AB despite trust's non-registration under Rajasthan Public Trust Act 1959. Tribunal held RPT Act registration not mandatory for tax registration as statutes operate independently without overriding effect. On FCRA compliance, matter remanded to CIT(E) with direction for trust to amend deed requiring prior MHA approval for foreign contributions. Regarding genuineness of activities, ITAT found CIT(E)'s observations self-contradictory and unsupported, noting trust had purchased land for hostel construction as new entity. Following precedent, mere lack of extensive operations at initial stage cannot justify registration denial. Registration granted subject to FCRA compliance amendment.
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