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 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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