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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After amendment to Explanation 1(c), eligibility as a venture capital undertaking must be determined strictly with reference to the SEBI Venture Capital Fund Regulations, 1996; on that regulatory and factual matrix the entity in question meets the regulatory description and is not within the negative list, so statutory eligibility is satisfied. Denial of exemption solely because commercial hospital operations had not commenced was rejected as inconsistent with the legislative aim to promote capital in sectors with inherent gestation. The income from the fund's qualifying investments therefore qualified for the statutory tax exemption.
After amendment to Explanation 1(c), eligibility as a venture capital undertaking must be determined strictly with reference to the SEBI Venture Capital Fund Regulations, 1996; on that regulatory and factual matrix the entity in question meets the regulatory description and is not within the negative list, so statutory eligibility is satisfied. Denial of exemption solely because commercial hospital operations had not commenced was rejected as inconsistent with the legislative aim to promote capital in sectors with inherent gestation. The income from the fund's qualifying investments therefore qualified for the statutory tax exemption.
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