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 HC dismissed the Revenue's challenge and upheld the CIT(A) and ITAT orders permitting the assessee's exemptions. The court held that the assessee, constituted under a historic trust and operating through a charitable SPV, is entitled to exemption under s.10(23C)(iv) notwithstanding the AO's addition under ss.11-12 and the application of ss.13(2)(b)/13(3)(b). Applying the rule of consistency, the HC found no change in law or material facts to justify departing from earlier grants of exemption in preceding assessment years and concluded no private benefit to trustees or individuals arose. The Revenue's appeal was therefore rejected and the exemption for the relevant AY was sustained.
The HC dismissed the Revenue's challenge and upheld the CIT(A) and ITAT orders permitting the assessee's exemptions. The court held that the assessee, constituted under a historic trust and operating through a charitable SPV, is entitled to exemption under s.10(23C)(iv) notwithstanding the AO's addition under ss.11-12 and the application of ss.13(2)(b)/13(3)(b). Applying the rule of consistency, the HC found no change in law or material facts to justify departing from earlier grants of exemption in preceding assessment years and concluded no private benefit to trustees or individuals arose. The Revenue's appeal was therefore rejected and the exemption for the relevant AY was sustained.
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