Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Eligibility for exemption u/s 10(23C)(iiiad) - claim not made in return of income - failure to furnish audit report in Form 10B - The Tribunal found that the institution, a society providing education, had spent more than 85% of its receipts towards charitable purposes. Despite a belated submission of the audit report, the institution was eligible for exemption under section 10(23C)(iiiad) of the Act. Consequently, the appeal was allowed, granting the institution the exemption it sought.
Eligibility for exemption u/s 10(23C)(iiiad) - claim not made in return of income - failure to furnish audit report in Form 10B - The Tribunal found that the institution, a society providing education, had spent more than 85% of its receipts towards charitable purposes. Despite a belated submission of the audit report, the institution was eligible for exemption under section 10(23C)(iiiad) of the Act. Consequently, the appeal was allowed, granting the institution the exemption it sought.
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