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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ITAT held that registration under section 12A(1)(ac)(iii) could not be denied merely because the trust had not carried out substantial activities in the relevant financial years, where the trust deed showed charitable objects and the record included audited accounts, returns, bank statements and donation details supporting genuineness. Applying Ananda Social & Educational Trust, the Tribunal noted that at the registration stage the inquiry is confined to the genuineness of the trust and its activities, and even proposed activities are relevant. The rejection of Form 10AB was therefore unsustainable, the consequential cancellation of provisional registration could not survive, and registration was directed to be granted.
ITAT held that registration under section 12A(1)(ac)(iii) could not be denied merely because the trust had not carried out substantial activities in the relevant financial years, where the trust deed showed charitable objects and the record included audited accounts, returns, bank statements and donation details supporting genuineness. Applying Ananda Social & Educational Trust, the Tribunal noted that at the registration stage the inquiry is confined to the genuineness of the trust and its activities, and even proposed activities are relevant. The rejection of Form 10AB was therefore unsustainable, the consequential cancellation of provisional registration could not survive, and registration was directed to be granted.
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