Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
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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