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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Omission of specific wording in Form No.10 does not automatically defeat accumulation under section 11(2) where the assessee substantiates the specific purpose and the tax officer was aware of and did not disbelieve the declaration; accumulation must, however, remain within the trust's objects, and supporting documents (object clauses, board resolution, project details) may cure a vague Form 10 description. Tribunal directed fresh consideration of the deduction claimed under section 11(2) for the relevant year in light of the materials furnished and precedents favouring substance over formal vagueness.
Omission of specific wording in Form No.10 does not automatically defeat accumulation under section 11(2) where the assessee substantiates the specific purpose and the tax officer was aware of and did not disbelieve the declaration; accumulation must, however, remain within the trust's objects, and supporting documents (object clauses, board resolution, project details) may cure a vague Form 10 description. Tribunal directed fresh consideration of the deduction claimed under section 11(2) for the relevant year in light of the materials furnished and precedents favouring substance over formal vagueness.
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