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 ITAT allowed the appeal of the assessee-trust, holding that it qualifies for registration under section 80G despite having some religious objects. The tribunal found the trust to be a composite religious-cum-charitable trust, with primary activities including running Annakshetra, Atithigruh, Gaushala, providing medical relief, and arranging mass marriages for the needy. The expenditure on religious activities was less than 5% of the total income, meeting the threshold under section 80G(5B), which permits registration if religious expenditure does not exceed 5% of income. The trust's funds were exclusively applied to charitable activities, and it submitted sufficient evidence to establish the genuineness of its activities. Consequently, the trust was deemed eligible for the benefits under section 80G, and the appeal was allowed.
The ITAT allowed the appeal of the assessee-trust, holding that it qualifies for registration under section 80G despite having some religious objects. The tribunal found the trust to be a composite religious-cum-charitable trust, with primary activities including running Annakshetra, Atithigruh, Gaushala, providing medical relief, and arranging mass marriages for the needy. The expenditure on religious activities was less than 5% of the total income, meeting the threshold under section 80G(5B), which permits registration if religious expenditure does not exceed 5% of income. The trust's funds were exclusively applied to charitable activities, and it submitted sufficient evidence to establish the genuineness of its activities. Consequently, the trust was deemed eligible for the benefits under section 80G, and the appeal was allowed.
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