Brand promotion expenditure requires an established associated-enterprise arrangement for transfer pricing, while management cross-charges must accoun...
Reassessment after the ordinary limitation period requires the escaped-income threshold and independent sanction, without expanding jurisdiction throu...
Transfer pricing comparability requires turnover and functional analysis, alongside rules on exempt-income disallowance and amalgamation goodwill depr...
Charitable exemption for fee-based citizen services requires an annual examination of whether charges are significantly above service costs and, if so, whether the applicable receipts threshold is exceeded under the first proviso to Section 2(15). Charges at cost or nominally above cost do not constitute trade, commerce or business, and registration under Section 12AA does not preclude the enquiry. Application of income under Section 11 is a separate enquiry: once accounts and relevant material are produced, denial must rest on their scrutiny rather than general observations. Operating expenditure ordinarily qualifies if the activity advances general public utility without attracting the proviso. A penalty under Section 271(1)(c) cannot survive independently of its foundational addition.
Charitable exemption for fee-based citizen services requires an annual examination of whether charges are significantly above service costs and, if so, whether the applicable receipts threshold is exceeded under the first proviso to Section 2(15). Charges at cost or nominally above cost do not constitute trade, commerce or business, and registration under Section 12AA does not preclude the enquiry. Application of income under Section 11 is a separate enquiry: once accounts and relevant material are produced, denial must rest on their scrutiny rather than general observations. Operating expenditure ordinarily qualifies if the activity advances general public utility without attracting the proviso. A penalty under Section 271(1)(c) cannot survive independently of its foundational addition.
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