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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HC upheld the ITAT's decision classifying the Trust as an Association of Persons (AOP), thereby disallowing interest paid to beneficiaries u/s 40(b). The AO found beneficiaries voluntarily pooled funds with clear intent to undertake project work and generate profits. The trust's self-declaration as an AOP and failure to rectify this status substantiated the classification. The court determined the findings were not perverse and the lower authorities' orders were legally justified, maintaining the disallowance of interest payments to beneficiaries.
HC upheld the ITAT's decision classifying the Trust as an Association of Persons (AOP), thereby disallowing interest paid to beneficiaries u/s 40(b). The AO found beneficiaries voluntarily pooled funds with clear intent to undertake project work and generate profits. The trust's self-declaration as an AOP and failure to rectify this status substantiated the classification. The court determined the findings were not perverse and the lower authorities' orders were legally justified, maintaining the disallowance of interest payments to beneficiaries.
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