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...
Return-processing adjustments to a charitable accumulation claim require compliance with the first proviso to section 143(1A), including an opportunity before the adjustment is made. Non-compliance vitiated the adjustment. Where an assessee's accumulated amount was incorrectly reported through an inadvertent return-form error, supported by an indemnity bond and a revised Form 10B, rectification required substantive consideration rather than rejection solely on a technical basis. The processing and rectification orders were set aside and remanded for consideration of the revised audit report, determination of correct income, and grant of admissible relief.
Return-processing adjustments to a charitable accumulation claim require compliance with the first proviso to section 143(1A), including an opportunity before the adjustment is made. Non-compliance vitiated the adjustment. Where an assessee's accumulated amount was incorrectly reported through an inadvertent return-form error, supported by an indemnity bond and a revised Form 10B, rectification required substantive consideration rather than rejection solely on a technical basis. The processing and rectification orders were set aside and remanded for consideration of the revised audit report, determination of correct income, and grant of admissible relief.
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