Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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.
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