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 SC upheld the High Court's ruling that organizing the Garba event during Navratri does not constitute a business activity under the proviso to section 2(15) read with section 13(8) of the Income Tax Act. The appellant's contention that the activity was carried out in a highly professional manner was rejected. The Court found no error in the HC's application of exemption under section 11. Consequently, the petition was dismissed along with all pending applications, affirming the tax exemption status of the activity.
The SC upheld the High Court's ruling that organizing the Garba event during Navratri does not constitute a business activity under the proviso to section 2(15) read with section 13(8) of the Income Tax Act. The appellant's contention that the activity was carried out in a highly professional manner was rejected. The Court found no error in the HC's application of exemption under section 11. Consequently, the petition was dismissed along with all pending applications, affirming the tax exemption status of the activity.
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