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 dismissed the Revenue's appeal, upholding the CIT(A)'s allowance of the trust's claim for exemption under s.11 and s.12 and rejecting the AO's invocation of s.13(1)(c) to treat the trust as an AOP. The Tribunal relied on a co-ordinate bench decision setting aside the cancellation of registration under s.12A/s.12AB and directed restoration of registration; prior judicial precedent and facts on record demonstrate that the trust deed permits the challenged leasing arrangement and that the issue is no longer open to re-investigation. Consequently, the assessee retains charitable status and entitlement to exemptions for the assessment year under review; Revenue's appeal is dismissed.
The ITAT dismissed the Revenue's appeal, upholding the CIT(A)'s allowance of the trust's claim for exemption under s.11 and s.12 and rejecting the AO's invocation of s.13(1)(c) to treat the trust as an AOP. The Tribunal relied on a co-ordinate bench decision setting aside the cancellation of registration under s.12A/s.12AB and directed restoration of registration; prior judicial precedent and facts on record demonstrate that the trust deed permits the challenged leasing arrangement and that the issue is no longer open to re-investigation. Consequently, the assessee retains charitable status and entitlement to exemptions for the assessment year under review; Revenue's appeal is dismissed.
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