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) - The Tribunal found that the provision allowing expenditure of up to five percent for religious purposes did not apply to this case. - The Tribunal found that the rejection lacked proper confrontation of observations and opportunity for the applicant to rebut. It emphasized that if any object of the trust is wholly or substantially of a religious nature, it falls outside the scope of Section 80G. The Tribunal allowed the appeal for statistical purposes and directed reconsideration by the Commissioner of Income Tax (Exemption) with proper opportunity for the assessee to present their case.
Registration u/s 80G(5) - The Tribunal found that the provision allowing expenditure of up to five percent for religious purposes did not apply to this case. - The Tribunal found that the rejection lacked proper confrontation of observations and opportunity for the applicant to rebut. It emphasized that if any object of the trust is wholly or substantially of a religious nature, it falls outside the scope of Section 80G. The Tribunal allowed the appeal for statistical purposes and directed reconsideration by the Commissioner of Income Tax (Exemption) with proper opportunity for the assessee to present their case.
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