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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Denial of exemption under sections 11 and 12 was sustained where the trust's receipts arose from government work contracts and not from donations or charitable activity; TDS under contract payments supported this commercial character. The article applies the charitable-purpose versus commercial-contract test and the incidental-business doctrine, finding contract income primary, not incidental, and absence of separate books fatal to exemption under the charitable activity definition. Use of trust funds for trustee benefit or payments on running account to specified persons attracts the prohibition on directing income to specified persons and loss of exemption with taxation at the maximum marginal rate.
Denial of exemption under sections 11 and 12 was sustained where the trust's receipts arose from government work contracts and not from donations or charitable activity; TDS under contract payments supported this commercial character. The article applies the charitable-purpose versus commercial-contract test and the incidental-business doctrine, finding contract income primary, not incidental, and absence of separate books fatal to exemption under the charitable activity definition. Use of trust funds for trustee benefit or payments on running account to specified persons attracts the prohibition on directing income to specified persons and loss of exemption with taxation at the maximum marginal rate.
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