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...
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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