Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Applicant seeking approval u/s 80G(5)(vi) - religious activities - it is clear that the CIT (E) has denied registration only on one ground violation of clause (iii) of sub-section (5) of Section 80G. The revenue cannot be allowed to make a new case. Even if we see that the ld counsel of the appellant has not contended that the Trust’s activities are centralised to only a few objects cannot be a ground for denying registration u/s.80G of the Act as this is not required to conduct activities on all the objects to get approval & registration u/s.80G and it is also not a requirement of section 80G of the Act to conduct activities on all the objects stated in the Trust Deed. - AT
Applicant seeking approval u/s 80G(5)(vi) - religious activities - it is clear that the CIT (E) has denied registration only on one ground violation of clause (iii) of sub-section (5) of Section 80G. The revenue cannot be allowed to make a new case. Even if we see that the ld counsel of the appellant has not contended that the Trust’s activities are centralised to only a few objects cannot be a ground for denying registration u/s.80G of the Act as this is not required to conduct activities on all the objects to get approval & registration u/s.80G and it is also not a requirement of section 80G of the Act to conduct activities on all the objects stated in the Trust Deed. - AT
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