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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Principal Commissioner's transfer of the assessee's PAN and associated 'case' to the Central charge carried all powers over the PAN, including power to cancel registration; therefore PCIT(C) had jurisdiction to cancel registration for prior and subsequent years. Cancellation under registration provisions was upheld on merits: the trust's recorded activities were non genuine and deviated from its objects by funding profit entities, promoting partisan content, and making payments without evidence of services, amounting to specified violations; such use of funds defeats charitable application and justifies loss of exemption. The appeal against cancellation is dismissed.
Principal Commissioner's transfer of the assessee's PAN and associated 'case' to the Central charge carried all powers over the PAN, including power to cancel registration; therefore PCIT(C) had jurisdiction to cancel registration for prior and subsequent years. Cancellation under registration provisions was upheld on merits: the trust's recorded activities were non genuine and deviated from its objects by funding profit entities, promoting partisan content, and making payments without evidence of services, amounting to specified violations; such use of funds defeats charitable application and justifies loss of exemption. The appeal against cancellation is dismissed.
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