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 Appellate Tribunal reviewed the rejection of registration u/s 12AB due to alleged violation of section 13(1)(b) as trust's objects were not solely for "SUNNI MUSLIMS." Tribunal found the trust to be religious cum charitable, with objects not limited to a specific religious community. The CIT(E) denied registration based on this restriction, invoking section 13(1)(b) and disallowing exemption u/s 11. Tribunal directed CIT(E) to reassess the registration application and grant it in accordance with the law. The appeal by the trust was allowed for statistical purposes.
The Appellate Tribunal reviewed the rejection of registration u/s 12AB due to alleged violation of section 13(1)(b) as trust's objects were not solely for "SUNNI MUSLIMS." Tribunal found the trust to be religious cum charitable, with objects not limited to a specific religious community. The CIT(E) denied registration based on this restriction, invoking section 13(1)(b) and disallowing exemption u/s 11. Tribunal directed CIT(E) to reassess the registration application and grant it in accordance with the law. The appeal by the trust was allowed for statistical purposes.
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