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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Corpus donations were held exempt under section 11(1)(d) because the decisive factor is the donor's specific direction, not whether the trust deed separately authorises acceptance of such contributions. The donor letters described the receipts as corpus donations, and the Revenue did not dispute their genuineness or show diversion from the trust's objects. The Tribunal also applied consistency, noting that similar receipts had been accepted in later years on the same facts. As corpus receipts were excluded from income, the alleged shortfall in application of income could not survive; in any event, Form No. 9A had been filed before completion of assessment, supporting accumulation relief.
Corpus donations were held exempt under section 11(1)(d) because the decisive factor is the donor's specific direction, not whether the trust deed separately authorises acceptance of such contributions. The donor letters described the receipts as corpus donations, and the Revenue did not dispute their genuineness or show diversion from the trust's objects. The Tribunal also applied consistency, noting that similar receipts had been accepted in later years on the same facts. As corpus receipts were excluded from income, the alleged shortfall in application of income could not survive; in any event, Form No. 9A had been filed before completion of assessment, supporting accumulation relief.
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