Customs Broker association membership becomes mandatory in the operating jurisdiction, with exclusive membership and limited compliance-time relaxatio...
Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
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The AO denied exemption u/s 11 to the assessee trust based on incriminating evidence of undisclosed income declared under PMGKY, systematic recovery of staff salaries, bogus corpus donations, and other fraudulent activities violating Sections 13(1)(c) and 13(1)(d). The trust's participation in PMGKY does not absolve it from wrongdoing. The CIT(A) failed to provide reasons justifying the trust's adherence to its objects. The accounts were unreliable due to the trustees' consistent involvement in fraud. The admission of undisclosed income under PMGKY and misuse of trust funds for taxes indicate deviation from charitable objectives. The AO's extrapolation was based on direct evidence of systematic fraud. The exemptions u/ss 11 and 12 were rightly denied, and income should be taxed at the maximum marginal rate u/s 164(2), excluding exemptions but giving credit for PMGKY disclosure after avoiding double additions.
The AO denied exemption u/s 11 to the assessee trust based on incriminating evidence of undisclosed income declared under PMGKY, systematic recovery of staff salaries, bogus corpus donations, and other fraudulent activities violating Sections 13(1)(c) and 13(1)(d). The trust's participation in PMGKY does not absolve it from wrongdoing. The CIT(A) failed to provide reasons justifying the trust's adherence to its objects. The accounts were unreliable due to the trustees' consistent involvement in fraud. The admission of undisclosed income under PMGKY and misuse of trust funds for taxes indicate deviation from charitable objectives. The AO's extrapolation was based on direct evidence of systematic fraud. The exemptions u/ss 11 and 12 were rightly denied, and income should be taxed at the maximum marginal rate u/s 164(2), excluding exemptions but giving credit for PMGKY disclosure after avoiding double additions.
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