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 denied registration u/s 12AB for trust due to non-compliance with statutory requirements. The tribunal found that the trust's object clause contained provisions inconsistent with section 11(1)(a) of the Income Tax Act. Despite being granted provisional registration, the final registration was rejected because the assessee failed to demonstrate amendment of objects or compliance with legal mandates. The Finance Act, 2022 amendments expanded grounds for registration denial, requiring strict adherence to legal frameworks. Consequently, both the primary registration application and the 80G registration were dismissed, with the tribunal rejecting all grounds raised by the assessee's authorized representative.
ITAT denied registration u/s 12AB for trust due to non-compliance with statutory requirements. The tribunal found that the trust's object clause contained provisions inconsistent with section 11(1)(a) of the Income Tax Act. Despite being granted provisional registration, the final registration was rejected because the assessee failed to demonstrate amendment of objects or compliance with legal mandates. The Finance Act, 2022 amendments expanded grounds for registration denial, requiring strict adherence to legal frameworks. Consequently, both the primary registration application and the 80G registration were dismissed, with the tribunal rejecting all grounds raised by the assessee's authorized representative.
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