Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Exemption u/s 11 - rejection of assessee’s application for registration u/s 12A - The Appellate Tribunal found that the rejection of the application was unjustified as it was based on suspicion without credible material. It emphasized that at the registration stage, the focus should be on determining whether the objectives of the institution are charitable, rather than questioning the expenditure incurred. It was observed that while the Commissioner did not doubt the charitable nature of the institution's objectives, the rejection was primarily based on concerns about promoting pharmaceutical businesses. However, the Tribunal asserted that educating and raising awareness about diseases like endocrine disorders is inherently charitable.
Exemption u/s 11 - rejection of assessee’s application for registration u/s 12A - The Appellate Tribunal found that the rejection of the application was unjustified as it was based on suspicion without credible material. It emphasized that at the registration stage, the focus should be on determining whether the objectives of the institution are charitable, rather than questioning the expenditure incurred. It was observed that while the Commissioner did not doubt the charitable nature of the institution's objectives, the rejection was primarily based on concerns about promoting pharmaceutical businesses. However, the Tribunal asserted that educating and raising awareness about diseases like endocrine disorders is inherently charitable.
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