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 assessee's appeal and held that, on the materials placed before the CIT(Exemption), the assessee's objects qualify as charitable within the meaning of s.2(15) and the activities of operating an approved school and college conform to those objects. The Tribunal found the genuineness of activities established, no statutory or regulatory violations shown, and the alleged failure to furnish details insufficient to deny relief. Consequently, the Tribunal held the assessee eligible for registration under s.12A read with s.12AB and directed CIT(Exemption)-Pune to grant registration to the assessee forthwith.
The ITAT allowed the assessee's appeal and held that, on the materials placed before the CIT(Exemption), the assessee's objects qualify as charitable within the meaning of s.2(15) and the activities of operating an approved school and college conform to those objects. The Tribunal found the genuineness of activities established, no statutory or regulatory violations shown, and the alleged failure to furnish details insufficient to deny relief. Consequently, the Tribunal held the assessee eligible for registration under s.12A read with s.12AB and directed CIT(Exemption)-Pune to grant registration to the assessee forthwith.
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