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...
The ITAT Ahmedabad addressed a case involving a delay in filing an appeal against the denial of registration u/s 12A and 80G, impacting exemption u/s 11. The Tribunal considered the reasons for the delay, noting the operational challenges faced by the assessee. Citing the principle that rules of procedure serve justice, the Tribunal condoned the delay in the appeal filing. Regarding the denial of registration, the Tribunal found that the assessee, an educational trust, was engaged in activities that warranted charitable status. The matter was remanded to the CIT for reevaluation. As the issue of exemption u/s 11 was linked to the registration matter, it was also remanded to the Assessing Officer for appropriate action post reevaluation of registration.
The ITAT Ahmedabad addressed a case involving a delay in filing an appeal against the denial of registration u/s 12A and 80G, impacting exemption u/s 11. The Tribunal considered the reasons for the delay, noting the operational challenges faced by the assessee. Citing the principle that rules of procedure serve justice, the Tribunal condoned the delay in the appeal filing. Regarding the denial of registration, the Tribunal found that the assessee, an educational trust, was engaged in activities that warranted charitable status. The matter was remanded to the CIT for reevaluation. As the issue of exemption u/s 11 was linked to the registration matter, it was also remanded to the Assessing Officer for appropriate action post reevaluation of registration.
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