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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Cancellation of registration under provisions concerning specified violations was quashed because the tax authority failed to identify any specified violation attributable to the trust; receipt of funds from an Indian citizen resident abroad, sent from personal savings through normal banking channels, was treated per FCRA guidance as not constituting foreign contribution, and suspicion without corroborative evidence cannot substitute for incriminating material. The tribunal emphasised that cancellation powers target misuse or failure to apply donations to objects of the trust, which was not shown here, and therefore the registration cancellation was unsustainable and the appeal allowed.
Cancellation of registration under provisions concerning specified violations was quashed because the tax authority failed to identify any specified violation attributable to the trust; receipt of funds from an Indian citizen resident abroad, sent from personal savings through normal banking channels, was treated per FCRA guidance as not constituting foreign contribution, and suspicion without corroborative evidence cannot substitute for incriminating material. The tribunal emphasised that cancellation powers target misuse or failure to apply donations to objects of the trust, which was not shown here, and therefore the registration cancellation was unsustainable and the appeal allowed.
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