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, set aside the orders of the lower authorities and directed that tax be computed at normal slab rates rather than the maximum marginal rate. The Tribunal held that the entity, being an unregistered religious trust for the relevant year and having filed Form-5 declaring income of Rs.1,50,272, fell within the threshold exemption of Rs.2,50,000 applicable to an AOP of its class; therefore section 164(2) (invoking MMR) was inapplicable. Section 164(3)(a) governs the present facts. The CPC's levy of MMR was held erroneous and all grounds raised by the appellant were allowed.
The ITAT allowed the appellant's appeal, set aside the orders of the lower authorities and directed that tax be computed at normal slab rates rather than the maximum marginal rate. The Tribunal held that the entity, being an unregistered religious trust for the relevant year and having filed Form-5 declaring income of Rs.1,50,272, fell within the threshold exemption of Rs.2,50,000 applicable to an AOP of its class; therefore section 164(2) (invoking MMR) was inapplicable. Section 164(3)(a) governs the present facts. The CPC's levy of MMR was held erroneous and all grounds raised by the appellant were allowed.
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