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 affirmed that the appellant charitable trust, which has not claimed registration or exemption under section 12A, is taxable as an Association of Persons for A.Y. 2023-24; the Tribunal found that the preconditions of the administrative circular were satisfied and therefore directed that income be assessed and tax computed at the slab rates applicable to an AOP with applicable surcharge and cess, rather than at trust-specific rates. The assessment is to be finalized accordingly, with tax liability determined under normal slab-rate provisions for an AOP for the relevant assessment year.
ITAT affirmed that the appellant charitable trust, which has not claimed registration or exemption under section 12A, is taxable as an Association of Persons for A.Y. 2023-24; the Tribunal found that the preconditions of the administrative circular were satisfied and therefore directed that income be assessed and tax computed at the slab rates applicable to an AOP with applicable surcharge and cess, rather than at trust-specific rates. The assessment is to be finalized accordingly, with tax liability determined under normal slab-rate provisions for an AOP for the relevant assessment year.
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