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 upheld that s.12AB permits registration only for trusts with genuine objects and activities, and remitted the matter to CIT(E) for fresh fact-finding rather than immediate cancellation. ITAT found the trust's acquisition of land and building a bona fide proposed activity in furtherance of its objects and rejected the finding that no charitable activity had been undertaken. ITAT directed CIT(E) to verify (i) the object clause of the donee trust receiving the lone donation, (ii) present status and use of the building purchased on 11/05/2024 and activities conducted thereon, (iii) the trust's current registered address, and (iv) any other enquiries necessary, and decide the registration issue in accordance with law.
ITAT upheld that s.12AB permits registration only for trusts with genuine objects and activities, and remitted the matter to CIT(E) for fresh fact-finding rather than immediate cancellation. ITAT found the trust's acquisition of land and building a bona fide proposed activity in furtherance of its objects and rejected the finding that no charitable activity had been undertaken. ITAT directed CIT(E) to verify (i) the object clause of the donee trust receiving the lone donation, (ii) present status and use of the building purchased on 11/05/2024 and activities conducted thereon, (iii) the trust's current registered address, and (iv) any other enquiries necessary, and decide the registration issue in accordance with law.
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