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...
Rejection of application for final approval u/s 80G(5)(iii) - The appellant, previously approved under Section 80G(5) of the Income Tax Act as a charitable institution, sought final approval following an amendment. Despite applying for provisional approval and subsequently for final approval, the application was rejected by the CIT(Exemption). The Tribunal clarified the interpretation of statutory provisions, emphasizing the application process for final approval and the applicability of CBDT Circulars. It held that the commencement of activities before provisional approval did not hinder the application process. The Tribunal directed the grant of provisional approval to the appellant and ensured the continuation of benefits under Section 80G of the Act.
Rejection of application for final approval u/s 80G(5)(iii) - The appellant, previously approved under Section 80G(5) of the Income Tax Act as a charitable institution, sought final approval following an amendment. Despite applying for provisional approval and subsequently for final approval, the application was rejected by the CIT(Exemption). The Tribunal clarified the interpretation of statutory provisions, emphasizing the application process for final approval and the applicability of CBDT Circulars. It held that the commencement of activities before provisional approval did not hinder the application process. The Tribunal directed the grant of provisional approval to the appellant and ensured the continuation of benefits under Section 80G of the Act.
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