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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Accumulation under section 11(2) could not be denied where the trust filed Form No. 10 within time, the stated purpose of repair, renovation and maintenance of temple-related premises fell within the trust's religious and charitable objects, and the accumulated funds were invested in fixed deposits with HDFC Bank, a permissible mode under section 11(5). Minor variations or general descriptions in Form No. 10 were held insufficient by themselves to defeat the benefit. Only the limited factual issue of verifying the dates of investment was remanded to the Assessing Officer for examination and consequential relief in accordance with law.
Accumulation under section 11(2) could not be denied where the trust filed Form No. 10 within time, the stated purpose of repair, renovation and maintenance of temple-related premises fell within the trust's religious and charitable objects, and the accumulated funds were invested in fixed deposits with HDFC Bank, a permissible mode under section 11(5). Minor variations or general descriptions in Form No. 10 were held insufficient by themselves to defeat the benefit. Only the limited factual issue of verifying the dates of investment was remanded to the Assessing Officer for examination and consequential relief in accordance with law.
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