Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
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...
Exemption u/s 11 - AO by invoking proviso to Section 2(15) and denying the exemption - Receipts from business activities exceeded the threshold of Rs. 10 lakhs and Rs. 20 lakhs - The ITAT directed the AO to assess whether the assessee's main activity, for which it was granted Section 12A registration, itself constituted trade, commerce, or business, or if the activities were intrinsically linked to the advancement of its charitable object.
Exemption u/s 11 - AO by invoking proviso to Section 2(15) and denying the exemption - Receipts from business activities exceeded the threshold of Rs. 10 lakhs and Rs. 20 lakhs - The ITAT directed the AO to assess whether the assessee's main activity, for which it was granted Section 12A registration, itself constituted trade, commerce, or business, or if the activities were intrinsically linked to the advancement of its charitable object.
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