Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Exemption under section 11(2) could not be denied solely because Form No. 10 described the accumulation purpose as "purpose of the trust" when no substantive breach of sections 11 or 13(1)(d) was shown. The Tribunal noted that the assessee remained registered under section 12A and that no violation was established in the relevant year, earlier years, or during utilisation of the accumulated income. Applying the principle in Bochasanwasi Shri Akshar Purshottam Public Charitable Trust, it held that greater specificity in Form No. 10 was not required in the absence of any statutory non-compliance. The disallowance and consequential taxation were deleted.
Exemption under section 11(2) could not be denied solely because Form No. 10 described the accumulation purpose as "purpose of the trust" when no substantive breach of sections 11 or 13(1)(d) was shown. The Tribunal noted that the assessee remained registered under section 12A and that no violation was established in the relevant year, earlier years, or during utilisation of the accumulated income. Applying the principle in Bochasanwasi Shri Akshar Purshottam Public Charitable Trust, it held that greater specificity in Form No. 10 was not required in the absence of any statutory non-compliance. The disallowance and consequential taxation were deleted.
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