Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated en...
Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unch...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
Automotive radio classification treats integrated infotainment features as supplementary, placing complete and qualifying unassembled units under the ...
Separate corporate personality prevents directors from being personally liable for company deposits without a guarantee or independent legal undertaki...
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Denial of charitable exemption under section 11 does not by itself justify taxing an educational trust's entire gross receipts. Taxable income must ordinarily reflect real income, determined after verification and allowance of genuine expenditure otherwise admissible in law, unless a provision requires taxation on a gross basis. The computation was restored to the assessing authority to examine the books and determine net taxable income after verifying the claimed expenditure; the appeal was partly allowed for statistical purposes.
Denial of charitable exemption under section 11 does not by itself justify taxing an educational trust's entire gross receipts. Taxable income must ordinarily reflect real income, determined after verification and allowance of genuine expenditure otherwise admissible in law, unless a provision requires taxation on a gross basis. The computation was restored to the assessing authority to examine the books and determine net taxable income after verifying the claimed expenditure; the appeal was partly allowed for statistical purposes.
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