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...
Corpus donations received by a charitable trust with a specific direction to form part of its corpus are treated as exempt capital receipts. A harmonious reading of the provisions on voluntary contributions, charitable-trust exemptions and the relevant CBDT circular supports exclusion of such receipts from taxable income. Where the trust is registered under the applicable charitable registration provisions and its income, excluding exempt corpus receipts, remains below the taxable limit, the audit requirement and filing of Form No. 10B are not attracted. Non-furnishing of Form No. 10B therefore does not defeat the exemption for qualifying corpus contributions.
Corpus donations received by a charitable trust with a specific direction to form part of its corpus are treated as exempt capital receipts. A harmonious reading of the provisions on voluntary contributions, charitable-trust exemptions and the relevant CBDT circular supports exclusion of such receipts from taxable income. Where the trust is registered under the applicable charitable registration provisions and its income, excluding exempt corpus receipts, remains below the taxable limit, the audit requirement and filing of Form No. 10B are not attracted. Non-furnishing of Form No. 10B therefore does not defeat the exemption for qualifying corpus contributions.
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