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...
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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