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 ITAT allowed the appellant's appeal for statistical purposes and remitted the matter to the CIT(E) with directions to admit and consider the additional evidence after affording the appellant an opportunity of hearing and decide the question of registration under s.12AA and allegations under s.13(1)(c) in accordance with law. The Tribunal held that the trust's objects could constitute benefit to the public (a cross-section) rather than to only its members, rejected the characterisation of the activities as inherently commercial given minimal volume, no fees and use of institutional infrastructure, and found that conclusions of non-genuineness were not warranted on the record.
The ITAT allowed the appellant's appeal for statistical purposes and remitted the matter to the CIT(E) with directions to admit and consider the additional evidence after affording the appellant an opportunity of hearing and decide the question of registration under s.12AA and allegations under s.13(1)(c) in accordance with law. The Tribunal held that the trust's objects could constitute benefit to the public (a cross-section) rather than to only its members, rejected the characterisation of the activities as inherently commercial given minimal volume, no fees and use of institutional infrastructure, and found that conclusions of non-genuineness were not warranted on the record.
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