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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A show cause notice for cancellation of charitable trust registration was valid where it referred to the search, survey, violations of the trust deed, misuse of the trust, and assessment findings; the trust's detailed reply showed adequate notice and opportunity to respond, and the Tribunal erred in treating the allegations as vague or isolating the Managing Trustee's conduct from the trust's misuse. The Court also held that the amended power to cancel registration could be invoked against a trust registered earlier, but the cancellation could not operate retrospectively from the original date of registration. The cancellation was upheld, but confined to the date of the cancellation order.
A show cause notice for cancellation of charitable trust registration was valid where it referred to the search, survey, violations of the trust deed, misuse of the trust, and assessment findings; the trust's detailed reply showed adequate notice and opportunity to respond, and the Tribunal erred in treating the allegations as vague or isolating the Managing Trustee's conduct from the trust's misuse. The Court also held that the amended power to cancel registration could be invoked against a trust registered earlier, but the cancellation could not operate retrospectively from the original date of registration. The cancellation was upheld, but confined to the date of the cancellation order.
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