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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Exemption for an educational institution under section 10(23C)(iiiab) was allowed because the Tribunal found the issue squarely covered by its earlier order in the assessee's own case, which had followed the Rajasthan High Court's view, and there was no change in facts for the years under consideration. On that basis, the Tribunal declined to depart from the earlier reasoning and sustained the assessee's claim to exemption as a wholly or substantially Government-financed educational institution. As a result, the additions linked to the assessment no longer survived and the revenue's appeals were dismissed.
Exemption for an educational institution under section 10(23C)(iiiab) was allowed because the Tribunal found the issue squarely covered by its earlier order in the assessee's own case, which had followed the Rajasthan High Court's view, and there was no change in facts for the years under consideration. On that basis, the Tribunal declined to depart from the earlier reasoning and sustained the assessee's claim to exemption as a wholly or substantially Government-financed educational institution. As a result, the additions linked to the assessment no longer survived and the revenue's appeals were dismissed.
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