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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An educational institution running a school was found to have gross receipts below the prescribed threshold, so it was legally entitled to exemption under section 10(23C)(iiiad). The Tribunal noted that even if exemption under section 10(23C)(vi) was not available, the alternative claim succeeded on the admitted facts of educational activity and receipts within the statutory limit. The alternative plea was therefore accepted, and the exemption under section 10(23C)(iiiad) was allowed, leaving the other grounds open.
An educational institution running a school was found to have gross receipts below the prescribed threshold, so it was legally entitled to exemption under section 10(23C)(iiiad). The Tribunal noted that even if exemption under section 10(23C)(vi) was not available, the alternative claim succeeded on the admitted facts of educational activity and receipts within the statutory limit. The alternative plea was therefore accepted, and the exemption under section 10(23C)(iiiad) was allowed, leaving the other grounds open.
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