Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
ITAT denied charitable trust exemption under section 11 due to undisclosed capitation fee receipts. The tribunal conclusively determined that management seat fees collected in cash constituted capitation fees, which are inherently non-charitable. Consistent with precedential rulings, the court rejected the trust's claim for tax exemption, emphasizing that charging capitation fees is incompatible with charitable objectives. The revenue's appeals were allowed, effectively disallowing the trust's exemption claims and rendering the unaccounted cash receipts taxable. Student affidavits were deemed irrelevant, as no individual would voluntarily incriminate themselves regarding fee payment practices.
ITAT denied charitable trust exemption under section 11 due to undisclosed capitation fee receipts. The tribunal conclusively determined that management seat fees collected in cash constituted capitation fees, which are inherently non-charitable. Consistent with precedential rulings, the court rejected the trust's claim for tax exemption, emphasizing that charging capitation fees is incompatible with charitable objectives. The revenue's appeals were allowed, effectively disallowing the trust's exemption claims and rendering the unaccounted cash receipts taxable. Student affidavits were deemed irrelevant, as no individual would voluntarily incriminate themselves regarding fee payment practices.
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