Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Voluntary contributions specifically earmarked for temple building construction and renovation were treated as corpus donations and therefore capital receipts. The Tribunal relied on donor lists, affidavits, receipts and audited accounts showing that the funds were received and applied for the stated construction purpose, and the Revenue did not rebut that material. It held that such earmarked corpus donations do not become taxable merely because the trust is unregistered under section 12A. Following prior ITAT authority, the addition for voluntary contributions was deleted as unsustainable.
Voluntary contributions specifically earmarked for temple building construction and renovation were treated as corpus donations and therefore capital receipts. The Tribunal relied on donor lists, affidavits, receipts and audited accounts showing that the funds were received and applied for the stated construction purpose, and the Revenue did not rebut that material. It held that such earmarked corpus donations do not become taxable merely because the trust is unregistered under section 12A. Following prior ITAT authority, the addition for voluntary contributions was deleted as unsustainable.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4814 
Join Channel 
