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)(vi) - The appellant, seeking registration under Section 80G(5) of the Income Tax Act, had their application rejected due to the mention of religious objects in the trust deed. The ITAT found that while Section 80G allows for charitable purposes, any object within the trust that is wholly or substantially religious renders it ineligible for benefits. It ordered a reevaluation of whether less than five percent of the total income was spent on religious activities, with the possibility of granting benefits if found compliant with the law. Thus, the appeal was allowed for statistical purposes.
Registration u/s 80G(5)(vi) - The appellant, seeking registration under Section 80G(5) of the Income Tax Act, had their application rejected due to the mention of religious objects in the trust deed. The ITAT found that while Section 80G allows for charitable purposes, any object within the trust that is wholly or substantially religious renders it ineligible for benefits. It ordered a reevaluation of whether less than five percent of the total income was spent on religious activities, with the possibility of granting benefits if found compliant with the law. Thus, the appeal was allowed for statistical purposes.
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