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 registration under section 12AB read with section 12A, holding that the assessee's objects are charitable within section 2(15), its activities are genuine and in furtherance of those objects, and no statutory violation was shown. The Tribunal found the assessee had satisfactorily evidenced short-term activities (including sanctioned school training camps, photographs and successful trainee participation) and that non-production of bills and vouchers was immaterial on the facts. The CIT (Exemption) was reproached for failing to apply independent mind to the applicant's submissions, and the registration refusal was set aside.
ITAT allowed the appeal and directed registration under section 12AB read with section 12A, holding that the assessee's objects are charitable within section 2(15), its activities are genuine and in furtherance of those objects, and no statutory violation was shown. The Tribunal found the assessee had satisfactorily evidenced short-term activities (including sanctioned school training camps, photographs and successful trainee participation) and that non-production of bills and vouchers was immaterial on the facts. The CIT (Exemption) was reproached for failing to apply independent mind to the applicant's submissions, and the registration refusal was set aside.
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