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 determined that salary paid to a related party was reasonable and commensurate with qualifications and services rendered. The court interpreted Section 13(1)(c) to mean that if compensation is objectively reasonable for services performed, it cannot be deemed as improper diversion of trust income to a prohibited person. Payments meeting standard market rates for legitimate services do not automatically trigger tax liability or disqualify charitable trust exemptions. The court rejected Revenue's argument that any payment to a related party inherently constitutes income diversion, instead focusing on the substantive reasonableness of compensation. Consequently, the ruling favored the assessee, maintaining the trust's tax-exempt status.
HC determined that salary paid to a related party was reasonable and commensurate with qualifications and services rendered. The court interpreted Section 13(1)(c) to mean that if compensation is objectively reasonable for services performed, it cannot be deemed as improper diversion of trust income to a prohibited person. Payments meeting standard market rates for legitimate services do not automatically trigger tax liability or disqualify charitable trust exemptions. The court rejected Revenue's argument that any payment to a related party inherently constitutes income diversion, instead focusing on the substantive reasonableness of compensation. Consequently, the ruling favored the assessee, maintaining the trust's tax-exempt status.
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