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 set aside the CIT(E)'s order denying registration under section 12AB, holding that the assessee trust is not solely for the benefit of a particular religion. The Tribunal found that the CIT(E) erred in concluding the trust was an AOP and not charitable based on the hostel's name referencing a specific community. The Range Head's report did not support the CIT(E)'s reasoning, and the trust deed demonstrated the hostel was open to girls from other communities as well. The Tribunal held the CIT(E)'s rejection was contrary to the trust deed and lacked factual basis. Consequently, the ITAT directed the CIT(E) to grant registration to the trust, allowing the assessee's appeal.
The ITAT set aside the CIT(E)'s order denying registration under section 12AB, holding that the assessee trust is not solely for the benefit of a particular religion. The Tribunal found that the CIT(E) erred in concluding the trust was an AOP and not charitable based on the hostel's name referencing a specific community. The Range Head's report did not support the CIT(E)'s reasoning, and the trust deed demonstrated the hostel was open to girls from other communities as well. The Tribunal held the CIT(E)'s rejection was contrary to the trust deed and lacked factual basis. Consequently, the ITAT directed the CIT(E) to grant registration to the trust, allowing the assessee's appeal.
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