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...
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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