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 of the assessee-trust and set aside the disallowance of exemption u/s 115BBC on anonymous donations. The Tribunal held that, though the AO and CIT(A) proceeded on the basis that the objects in the original Memorandum were only charitable and not religious, they failed to consider the amended deed dated 07.05.2014. The amended deed, duly filed and on record, established that the trust was created for both religious and charitable purposes. Consequently, the trust satisfied the statutory requirement and was held entitled to exemption u/s 115BBC.
ITAT allowed the appeal of the assessee-trust and set aside the disallowance of exemption u/s 115BBC on anonymous donations. The Tribunal held that, though the AO and CIT(A) proceeded on the basis that the objects in the original Memorandum were only charitable and not religious, they failed to consider the amended deed dated 07.05.2014. The amended deed, duly filed and on record, established that the trust was created for both religious and charitable purposes. Consequently, the trust satisfied the statutory requirement and was held entitled to exemption u/s 115BBC.
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