Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Exemption u/s 11 - Charitable activity u/s 2(15) - Commercial activity - Citing past decisions favorable to the trust under similar assessments, the Tribunal reiterated that activities generating income do not automatically disqualify an entity from being charitable if the primary purpose is charitable and the commercial activities are incidental. It was highlighted that the trust's income was indeed applied towards its stated charitable purposes, fulfilling the criteria for exemption under Section 11.
Exemption u/s 11 - Charitable activity u/s 2(15) - Commercial activity - Citing past decisions favorable to the trust under similar assessments, the Tribunal reiterated that activities generating income do not automatically disqualify an entity from being charitable if the primary purpose is charitable and the commercial activities are incidental. It was highlighted that the trust's income was indeed applied towards its stated charitable purposes, fulfilling the criteria for exemption under Section 11.
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