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 appeal, set aside the impugned order of the Commissioner and held the assessee's application for regular registration u/s 80G(5) to be within limitation. The Tribunal found the proviso's first clause-requiring filing six months prior to expiry of provisional approval-applicable because provisional registration extended to A.Y. 2025-26 and the application was filed on 30.09.2024; the second clause (six months from commencement of activities) was inapplicable to an entity which commenced activities in 1952. The matter is remitted to the Commissioner to treat the application as valid and decide merits afresh. Appeal allowed for statistical purposes.
ITAT allowed the appeal, set aside the impugned order of the Commissioner and held the assessee's application for regular registration u/s 80G(5) to be within limitation. The Tribunal found the proviso's first clause-requiring filing six months prior to expiry of provisional approval-applicable because provisional registration extended to A.Y. 2025-26 and the application was filed on 30.09.2024; the second clause (six months from commencement of activities) was inapplicable to an entity which commenced activities in 1952. The matter is remitted to the Commissioner to treat the application as valid and decide merits afresh. Appeal allowed for statistical purposes.
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