Charitable sports promotion: sponsorship receipts alone did not defeat registration where funds supported tournaments and player development activitie...
Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as busi...
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require...
Transfer-pricing adjustments must reflect functional comparability, working-capital effects, and avoid duplicating interest on associated-enterprise r...
Revisional jurisdiction under section 264 extends to relief omitted from a return where a charitable trust later identifies an error causing over-assessment. Voluntary disclosure of income as taxable does not bar reconsideration if the trust disclosed the capital gains and relevant particulars without suppressing material; the revisional authority must examine entitlement under law. For charitable-trust capital gains, reinvestment of net sale consideration in a bank fixed deposit for six months or more is treated as acquisition of another capital asset under Instruction No. 883. Conditions under public-trust law cannot be imported to deny this standalone exemption.
Revisional jurisdiction under section 264 extends to relief omitted from a return where a charitable trust later identifies an error causing over-assessment. Voluntary disclosure of income as taxable does not bar reconsideration if the trust disclosed the capital gains and relevant particulars without suppressing material; the revisional authority must examine entitlement under law. For charitable-trust capital gains, reinvestment of net sale consideration in a bank fixed deposit for six months or more is treated as acquisition of another capital asset under Instruction No. 883. Conditions under public-trust law cannot be imported to deny this standalone exemption.
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