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...
Registration u/s 12AA - Gujarat Cricket Association[GCA] - Merely because an activity is performed in an organized manner, that alone, will not make such activities as business/commercial activity. The profit motive is one essential ingredient which is apparently missing in the case on hand - The nature of the activities of the assessee cannot take its colour from the nature of the activities of the donor.
Registration u/s 12AA - Gujarat Cricket Association[GCA] - Merely because an activity is performed in an organized manner, that alone, will not make such activities as business/commercial activity. The profit motive is one essential ingredient which is apparently missing in the case on hand - The nature of the activities of the assessee cannot take its colour from the nature of the activities of the donor.
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