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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HC disposed of the writ petitions by holding that exemption under Section 10(23BBA) of the Income-tax Act is confined to bodies or authorities constituted, established or appointed under a Central, State or Provincial enactment. Income directly belonging to temples or other public religious or charitable endowments, even if administered by such statutory bodies, is not per se eligible for this exemption. If the disputed income is that of the administrative body itself, petitioners may claim exemption, subject to satisfaction of statutory conditions, before the competent authorities. The question whether the income pertains to the temple or the administrative body is left to be determined in appropriate proceedings.
HC disposed of the writ petitions by holding that exemption under Section 10(23BBA) of the Income-tax Act is confined to bodies or authorities constituted, established or appointed under a Central, State or Provincial enactment. Income directly belonging to temples or other public religious or charitable endowments, even if administered by such statutory bodies, is not per se eligible for this exemption. If the disputed income is that of the administrative body itself, petitioners may claim exemption, subject to satisfaction of statutory conditions, before the competent authorities. The question whether the income pertains to the temple or the administrative body is left to be determined in appropriate proceedings.
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