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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PCIT (Central), Gurgaon lacked subject-matter jurisdiction to decide renewal of charitable registration under section 12A(1)(ac)(ii) because the competent authority was the Commissioner of Income Tax (Exemptions), Chandigarh under the relevant CBDT notification. The Tribunal also held that renewal proceedings are confined to the genuineness of the activities and compliance with other laws relevant to the objects, and cannot be converted into cancellation proceedings. As the assessees were engaged in education, and the record did not discredit the genuineness of those charitable activities, past or minor irregularities could not justify refusal of renewal. The rejection orders were set aside and renewal directed.
PCIT (Central), Gurgaon lacked subject-matter jurisdiction to decide renewal of charitable registration under section 12A(1)(ac)(ii) because the competent authority was the Commissioner of Income Tax (Exemptions), Chandigarh under the relevant CBDT notification. The Tribunal also held that renewal proceedings are confined to the genuineness of the activities and compliance with other laws relevant to the objects, and cannot be converted into cancellation proceedings. As the assessees were engaged in education, and the record did not discredit the genuineness of those charitable activities, past or minor irregularities could not justify refusal of renewal. The rejection orders were set aside and renewal directed.
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