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 AT allowed the appeals, holding that the inter-scheme transfers (ISTs) undertaken by the AMC did not contravene applicable MF Regulations or the July 27, 2000 circular. The Tribunal found ISTs permissible, specific conditions in Schedule-VII and due-diligence processes were satisfied, reasons were recorded, and no fresh market purchases were made; there was no evidence of private gain, integrity breaches by trustees/AMC, or proven contravention of Para-6 or Para-8. Applying the principle generalia specialibus non derogant, specific IST provisions prevailed over general code provisions, and the Assessing Officer could not substitute his judgment for professional investment decisions. Appeals accordingly allowed.
The AT allowed the appeals, holding that the inter-scheme transfers (ISTs) undertaken by the AMC did not contravene applicable MF Regulations or the July 27, 2000 circular. The Tribunal found ISTs permissible, specific conditions in Schedule-VII and due-diligence processes were satisfied, reasons were recorded, and no fresh market purchases were made; there was no evidence of private gain, integrity breaches by trustees/AMC, or proven contravention of Para-6 or Para-8. Applying the principle generalia specialibus non derogant, specific IST provisions prevailed over general code provisions, and the Assessing Officer could not substitute his judgment for professional investment decisions. Appeals accordingly allowed.
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