Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Rejection of approvals u/s 80G - approval application filed belatedly - The Tribunal noted that the CBDT had extended deadlines for filing applications for registration or approval in light of genuine hardships faced by charitable entities. This was a significant consideration, indicating a recognition of practical difficulties and an intent to mitigate them. The Tribunal held that the timelines prescribed under clause (iii) of the first proviso to section 80G(5) should be treated as directory rather than mandatory, especially in light of the transitional nature of amendments introduced by the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020. (TOLA)
Rejection of approvals u/s 80G - approval application filed belatedly - The Tribunal noted that the CBDT had extended deadlines for filing applications for registration or approval in light of genuine hardships faced by charitable entities. This was a significant consideration, indicating a recognition of practical difficulties and an intent to mitigate them. The Tribunal held that the timelines prescribed under clause (iii) of the first proviso to section 80G(5) should be treated as directory rather than mandatory, especially in light of the transitional nature of amendments introduced by the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020. (TOLA)
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