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...
Registration applied u/s 80G - The Tribunal examined the provisions of Section 80G(5) of the Act and clarified the interpretation of CBDT Circulars related to application deadlines. It emphasized the importance of allowing institutions already engaged in charitable activities to obtain final registration under Section 80G(5)(iii) of the Act, regardless of when they commenced activities. Based on its findings, the Tribunal set aside the Commissioner's decision and directed the granting of provisional approval to the assessee, subject to eligibility.
Registration applied u/s 80G - The Tribunal examined the provisions of Section 80G(5) of the Act and clarified the interpretation of CBDT Circulars related to application deadlines. It emphasized the importance of allowing institutions already engaged in charitable activities to obtain final registration under Section 80G(5)(iii) of the Act, regardless of when they commenced activities. Based on its findings, the Tribunal set aside the Commissioner's decision and directed the granting of provisional approval to the assessee, subject to eligibility.
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