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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ITAT allowed the assessee's appeals, set aside the CIT(E) order denying registration under sections 12AB and 80G, and directed the CIT(E) to permit rectification of the incorrectly selected clause/sub-clause in the application form. The Tribunal found the filing error non-fatal, accepted the assessee's explanation and prayer for amendment, and ordered CIT(E) to adjudicate the registration application on its merits thereafter. Consequentially, the matter is remitted for fresh consideration and decision in accordance with law. The appeals are allowed for statistical purposes.
ITAT allowed the assessee's appeals, set aside the CIT(E) order denying registration under sections 12AB and 80G, and directed the CIT(E) to permit rectification of the incorrectly selected clause/sub-clause in the application form. The Tribunal found the filing error non-fatal, accepted the assessee's explanation and prayer for amendment, and ordered CIT(E) to adjudicate the registration application on its merits thereafter. Consequentially, the matter is remitted for fresh consideration and decision in accordance with law. The appeals are allowed for statistical purposes.
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