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...
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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 appellant's claims: it held the authority's activities constituted charitable purposes within s.2(15) and were therefore exempt under ss.11 and 12, the first proviso to s.2(15) not applying; the auctioning of sites was incidental to public purpose and not commercially motivated. Consequentially prior-period expenses and assets written off qualify as application of income and are allowable; payments for electrical deposits and committee accommodation are allowable pending any reversal; slum-cess disallowance under s.43B does not arise given s.11 exemption; and interest on delayed service-tax payment is deductible under s.37. The revenue's disallowances were rejected absent contrary higher-forum authority or distinguishing material.
The ITAT allowed the appellant's claims: it held the authority's activities constituted charitable purposes within s.2(15) and were therefore exempt under ss.11 and 12, the first proviso to s.2(15) not applying; the auctioning of sites was incidental to public purpose and not commercially motivated. Consequentially prior-period expenses and assets written off qualify as application of income and are allowable; payments for electrical deposits and committee accommodation are allowable pending any reversal; slum-cess disallowance under s.43B does not arise given s.11 exemption; and interest on delayed service-tax payment is deductible under s.37. The revenue's disallowances were rejected absent contrary higher-forum authority or distinguishing material.
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