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 case pertains to the refusal of registration u/s 12AA for charitable activities u/s 2(15). The Commissioner of Income Tax observed that the society was not imparting education as a charitable purpose within the meaning of Section 2(15), despite being granted approval u/s 10(23)(vi). The court held that the powers to cancel registration u/s 12AA(3) can only be applied prospectively, not retrospectively, as per precedents. Since the institute is a registered educational trust and utilizes earnings for education, it cannot be denied registration u/s 12AA. The High Court dismissed the appeal, finding no error by the Income Tax Appellate Tribunal in granting registration u/s 12AA.
The case pertains to the refusal of registration u/s 12AA for charitable activities u/s 2(15). The Commissioner of Income Tax observed that the society was not imparting education as a charitable purpose within the meaning of Section 2(15), despite being granted approval u/s 10(23)(vi). The court held that the powers to cancel registration u/s 12AA(3) can only be applied prospectively, not retrospectively, as per precedents. Since the institute is a registered educational trust and utilizes earnings for education, it cannot be denied registration u/s 12AA. The High Court dismissed the appeal, finding no error by the Income Tax Appellate Tribunal in granting registration u/s 12AA.
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