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 appellant's appeal and directed grant of registration under s.12AB, holding the association's objects fall within "charitable purpose" as defined in s.2(15). The Tribunal found the association was formed to organize, unite and protect the common commercial interests of members engaged in a particular trade, with benefits incidental to the trade rather than conferring private pecuniary gain on specified individuals. Applying established precedent that trade-promoting bodies advancing industry or commerce can satisfy charitable purpose when public utility is served, the bench concluded the appellant's activities are analogous and not confined to private benefit, and therefore eligible for registration under s.12AB.
ITAT allowed the appellant's appeal and directed grant of registration under s.12AB, holding the association's objects fall within "charitable purpose" as defined in s.2(15). The Tribunal found the association was formed to organize, unite and protect the common commercial interests of members engaged in a particular trade, with benefits incidental to the trade rather than conferring private pecuniary gain on specified individuals. Applying established precedent that trade-promoting bodies advancing industry or commerce can satisfy charitable purpose when public utility is served, the bench concluded the appellant's activities are analogous and not confined to private benefit, and therefore eligible for registration under s.12AB.
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