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 allowed appeal concerning approval under s.10(23C)(vi) for educational institution converted from society to Section 8 Company. CIT(E) rejected approval citing new objects including medical facilities in memorandum. ITAT held medical centers and clinics are integral to medical education, providing practical training. No evidence showed assessee conducted activities beyond education. Original educational operations continued as going concern post-conversion. Matter remanded to CIT(E) to verify revised objects and grant approval after confirming removal of contested clauses. Conversion from society to company did not alter educational nature of institution's activities.
ITAT allowed appeal concerning approval under s.10(23C)(vi) for educational institution converted from society to Section 8 Company. CIT(E) rejected approval citing new objects including medical facilities in memorandum. ITAT held medical centers and clinics are integral to medical education, providing practical training. No evidence showed assessee conducted activities beyond education. Original educational operations continued as going concern post-conversion. Matter remanded to CIT(E) to verify revised objects and grant approval after confirming removal of contested clauses. Conversion from society to company did not alter educational nature of institution's activities.
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