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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Transfer of sale proceeds by a registered charitable trust to other charitable societies constitutes application of income for charitable purposes, and such inter trust donations do not justify cancellation or denial of registration under the tax regime. Relying on precedent, the tribunal affirmed that unsupported allegations about the donees do not vitiate donations and the trust's registration remains operative; accordingly, the trust retains entitlement to exemptions under sections governing charitable institutions and the Revenue's appeal was dismissed.
Transfer of sale proceeds by a registered charitable trust to other charitable societies constitutes application of income for charitable purposes, and such inter trust donations do not justify cancellation or denial of registration under the tax regime. Relying on precedent, the tribunal affirmed that unsupported allegations about the donees do not vitiate donations and the trust's registration remains operative; accordingly, the trust retains entitlement to exemptions under sections governing charitable institutions and the Revenue's appeal was dismissed.
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