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 80G(5) - The rejection was based on allegations of discrepancy in the organization's name, violation of FCRA provisions, and involvement in religious conversion activities. - Providing benefit to any particular religion, caste or community - The Assessee contested these allegations, citing clerical errors, lack of evidence, and violation of natural justice principles. - The Tribunal criticized the lack of confrontation of allegations with the Assessee. They deemed it a violation of natural justice and directed the CIT(E) to provide the Assessee with all relevant information and explanations before reaching a conclusion.
Registration u/s 80G(5) - The rejection was based on allegations of discrepancy in the organization's name, violation of FCRA provisions, and involvement in religious conversion activities. - Providing benefit to any particular religion, caste or community - The Assessee contested these allegations, citing clerical errors, lack of evidence, and violation of natural justice principles. - The Tribunal criticized the lack of confrontation of allegations with the Assessee. They deemed it a violation of natural justice and directed the CIT(E) to provide the Assessee with all relevant information and explanations before reaching a conclusion.
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