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 and directed the AO to admit exemption under s.11/12 for the appellant for AY 2018-19 on the basis of the first proviso to s.12A(2), holding that subsequent grant of registration u/s 12AA (during pending assessment) entitles the trust to s.11/12 benefits for the preceding year subject to verification and no change in objects/activities; the tribunal rejected the CIT(A)'s reasons, noting the proviso was operative for the relevant year, and remitted the matter to the AO to afford the appellant opportunity to furnish particulars and to compute and verify the admissible exemption (appeal allowed for statistical purposes).
ITAT allowed the appeal and directed the AO to admit exemption under s.11/12 for the appellant for AY 2018-19 on the basis of the first proviso to s.12A(2), holding that subsequent grant of registration u/s 12AA (during pending assessment) entitles the trust to s.11/12 benefits for the preceding year subject to verification and no change in objects/activities; the tribunal rejected the CIT(A)'s reasons, noting the proviso was operative for the relevant year, and remitted the matter to the AO to afford the appellant opportunity to furnish particulars and to compute and verify the admissible exemption (appeal allowed for statistical purposes).
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