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 ITAT dismissed the assessee's appeal regarding donations made to an unregistered trust under section 12A, affirming that exemption under section 11(1)(a) requires the recipient entity to be registered. The assessee failed to provide evidence that expenditures were for charitable purposes. However, the Tribunal allowed various expenses as valid application of income, including interest on TDS, statutory penalties, gifts, cultural expenditures, and ITC write-offs, considering them incidental to charitable activities based on precedents including CIT v. Trustee of H.E.H. the Nizam's Supplemental Religious Endowment Trust and CIT v. Surat Art Silk Cloth Manufacturers Association. The ITAT also permitted accumulation of income under section 11(2), ruling that bank deposits and lien-free FDRs qualify as investments under section 11(5).
The ITAT dismissed the assessee's appeal regarding donations made to an unregistered trust under section 12A, affirming that exemption under section 11(1)(a) requires the recipient entity to be registered. The assessee failed to provide evidence that expenditures were for charitable purposes. However, the Tribunal allowed various expenses as valid application of income, including interest on TDS, statutory penalties, gifts, cultural expenditures, and ITC write-offs, considering them incidental to charitable activities based on precedents including CIT v. Trustee of H.E.H. the Nizam's Supplemental Religious Endowment Trust and CIT v. Surat Art Silk Cloth Manufacturers Association. The ITAT also permitted accumulation of income under section 11(2), ruling that bank deposits and lien-free FDRs qualify as investments under section 11(5).
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