Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
Grant of approval u/s. 80G(5) - denial of approval as application was not filed within six months from the date of grant of provisional approval - The Tribunal observed that the Act does not empower it to condone delays in such matters, unlike provisions for other sections. Citing legal precedents, it affirmed that without explicit statutory authority, delay condonation is not permissible. Consequently, the denial of approval u/s. 80G(5) by the ld. CIT, Exemption was upheld.
Grant of approval u/s. 80G(5) - denial of approval as application was not filed within six months from the date of grant of provisional approval - The Tribunal observed that the Act does not empower it to condone delays in such matters, unlike provisions for other sections. Citing legal precedents, it affirmed that without explicit statutory authority, delay condonation is not permissible. Consequently, the denial of approval u/s. 80G(5) by the ld. CIT, Exemption was upheld.
Note: It is a system-generated summary and is for quick reference only.