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...
Territorial and subject-matter jurisdiction remains necessary for cancellation of charitable registration; designation as a Principal Commissioner or Commissioner does not itself confer authority over exemption registration. Exemption jurisdiction continues with the designated exemption authority unless lawfully transferred. Centralisation of group assessments for investigation does not establish transfer of registration jurisdiction without a transfer order, notification, or other jurisdictional instrument assigning an Assessing Officer under the relevant Central Commissioner. Notification No. 70/2014 applies only where such assignment is proved. On these principles, cancellation of registration for want of jurisdiction was quashed and the original registration restored, while the underlying allegations and retrospective-cancellation issue remained unresolved.
Territorial and subject-matter jurisdiction remains necessary for cancellation of charitable registration; designation as a Principal Commissioner or Commissioner does not itself confer authority over exemption registration. Exemption jurisdiction continues with the designated exemption authority unless lawfully transferred. Centralisation of group assessments for investigation does not establish transfer of registration jurisdiction without a transfer order, notification, or other jurisdictional instrument assigning an Assessing Officer under the relevant Central Commissioner. Notification No. 70/2014 applies only where such assignment is proved. On these principles, cancellation of registration for want of jurisdiction was quashed and the original registration restored, while the underlying allegations and retrospective-cancellation issue remained unresolved.
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