Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
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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