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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Running a play school and kindergarten was treated as "education" under section 2(15) because the Tribunal found the activity involved organised pre-primary instruction through qualified nursery teachers, not mere informal care. On that basis, the institution's objects were held charitable for registration purposes and entitlement to section 12A registration followed. At the registration stage, the inquiry is limited to the objects of the institution and the genuineness of its activities; any alleged section 13 violation, including payments to related parties, is not ative for registration and must be examined, if relevant, in assessment proceedings. The refusal of registration on that ground was therefore unjustified.
Running a play school and kindergarten was treated as "education" under section 2(15) because the Tribunal found the activity involved organised pre-primary instruction through qualified nursery teachers, not mere informal care. On that basis, the institution's objects were held charitable for registration purposes and entitlement to section 12A registration followed. At the registration stage, the inquiry is limited to the objects of the institution and the genuineness of its activities; any alleged section 13 violation, including payments to related parties, is not ative for registration and must be examined, if relevant, in assessment proceedings. The refusal of registration on that ground was therefore unjustified.
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