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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Registration under section 12AB could not be refused merely because a charitable trust was at an initial stage and had conducted only a medical conference. The Tribunal held that, for registration, the Commissioner must examine both the objects and the proposed activities of the trust. The deed showed charitable objects directed to medical relief, public awareness, treatment support, assistance to students, old age homes and allied public causes, and the asset-transfer clause on dissolution was inconsistent with a mutual concern. Limited commencement of activities was not, by itself, a disqualifying violation. The mutuality finding was therefore unsustainable, and the application was to be processed for registration.
Registration under section 12AB could not be refused merely because a charitable trust was at an initial stage and had conducted only a medical conference. The Tribunal held that, for registration, the Commissioner must examine both the objects and the proposed activities of the trust. The deed showed charitable objects directed to medical relief, public awareness, treatment support, assistance to students, old age homes and allied public causes, and the asset-transfer clause on dissolution was inconsistent with a mutual concern. Limited commencement of activities was not, by itself, a disqualifying violation. The mutuality finding was therefore unsustainable, and the application was to be processed for registration.
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