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...
A one-time fund-raising programme through coupon sales and a lucky draw was not treated as business activity where the surplus was applied to the trust's charitable objects; applying the dominant object test, the HC held that no specified violation under section 12AB(4) arose and registration could not be refused on that basis. The Court also accepted that disqualifications under section 13 are to be examined in assessment proceedings, not at the registration stage, so section 13 could not be invoked to deny registration under section 12AB. Finding no substantial question of law, the appeal was dismissed.
A one-time fund-raising programme through coupon sales and a lucky draw was not treated as business activity where the surplus was applied to the trust's charitable objects; applying the dominant object test, the HC held that no specified violation under section 12AB(4) arose and registration could not be refused on that basis. The Court also accepted that disqualifications under section 13 are to be examined in assessment proceedings, not at the registration stage, so section 13 could not be invoked to deny registration under section 12AB. Finding no substantial question of law, the appeal was dismissed.
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