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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"Gorakhpur Industrial Development Authority", constituted under the Uttar Pradesh Industrial Area Development Act, 1976, is notified for the purposes of section 10(46A) of the Income-tax Act, 1961, so that its specified income falls within the exemption framework under that clause. The notification applies from assessment year 2025-26, subject to the continuing condition that the authority remains constituted under the 1976 Act and continues to have one or more purposes specified in section 10(46A)(a); failing this, the exemption would not operate.
"Gorakhpur Industrial Development Authority", constituted under the Uttar Pradesh Industrial Area Development Act, 1976, is notified for the purposes of section 10(46A) of the Income-tax Act, 1961, so that its specified income falls within the exemption framework under that clause. The notification applies from assessment year 2025-26, subject to the continuing condition that the authority remains constituted under the 1976 Act and continues to have one or more purposes specified in section 10(46A)(a); failing this, the exemption would not operate.
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