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 assessee's appeal and set aside the order of the CIT(E) rejecting registration under section 12A. The Tribunal held that the assessee's activities constitute "advancement of any other object of general public utility" within the meaning of section 2(15), with no profit motive, and therefore qualify as charitable purposes. It ruled that the CIT(E) erred in treating the assessee as non-charitable merely for watching business interests of its members. CIT(E) was directed to grant regular registration under section 12A(1)(ac)(vi) forthwith, as applied in Form 10AB.
ITAT allowed the assessee's appeal and set aside the order of the CIT(E) rejecting registration under section 12A. The Tribunal held that the assessee's activities constitute "advancement of any other object of general public utility" within the meaning of section 2(15), with no profit motive, and therefore qualify as charitable purposes. It ruled that the CIT(E) erred in treating the assessee as non-charitable merely for watching business interests of its members. CIT(E) was directed to grant regular registration under section 12A(1)(ac)(vi) forthwith, as applied in Form 10AB.
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