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...
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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 under section 11 was sustained because the assessee's letting of an auditorium was held to be merely incidental to its dominant charitable objects of education and medical relief, undertaken to augment funds. The Tribunal followed its decision in the assessee's own earlier year on identical facts and found that the activity did not amount to carrying on business, so the proviso to section 2(15) was not attracted. The Commissioner (Appeals)'s grant of relief under section 11 therefore required no interference, and the exemption was upheld for both assessment years.
Exemption under section 11 was sustained because the assessee's letting of an auditorium was held to be merely incidental to its dominant charitable objects of education and medical relief, undertaken to augment funds. The Tribunal followed its decision in the assessee's own earlier year on identical facts and found that the activity did not amount to carrying on business, so the proviso to section 2(15) was not attracted. The Commissioner (Appeals)'s grant of relief under section 11 therefore required no interference, and the exemption was upheld for both assessment years.
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