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...
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Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Medical relief is a distinct charitable purpose, so the commerciality test in the proviso to section 2(15) cannot be mechanically applied to a hospital whose object is medical relief; surplus and organised operations do not by themselves make its activities non-charitable, and the rejection of renewal on that basis was unsustainable. Alleged breach of the Maharashtra Public Trusts Act and the IPF Scheme could not be independently adjudicated in renewal proceedings without an adverse determination by the competent authority; low bed occupancy or incomplete data did not establish violation. Renewal proceedings also could not be converted into retrospective cancellation from the original grant absent findings of fraud, misrepresentation, concealment, suppression, or void inception, so the cancellation was set aside.
Medical relief is a distinct charitable purpose, so the commerciality test in the proviso to section 2(15) cannot be mechanically applied to a hospital whose object is medical relief; surplus and organised operations do not by themselves make its activities non-charitable, and the rejection of renewal on that basis was unsustainable. Alleged breach of the Maharashtra Public Trusts Act and the IPF Scheme could not be independently adjudicated in renewal proceedings without an adverse determination by the competent authority; low bed occupancy or incomplete data did not establish violation. Renewal proceedings also could not be converted into retrospective cancellation from the original grant absent findings of fraud, misrepresentation, concealment, suppression, or void inception, so the cancellation was set aside.
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