Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
The ITAT upheld the CIT(A)'s order allowing deduction u/s 11, following the 'Principle of Consistency'. Despite payments to specified persons u/s 13(1)(c), the Revenue had allowed exemption in earlier years without adverse remarks. Applying Radhasoami Satsang, the ITAT ruled that without a change in facts or the earlier order being arbitrary/perverse, the Revenue cannot deviate from its consistent stance in subsequent years. Certainty and finality are essential, mandating consistent treatment unless material differences exist. The DR failed to demonstrate any infirmity or factual changes, leading to the decision against the Revenue.
The ITAT upheld the CIT(A)'s order allowing deduction u/s 11, following the 'Principle of Consistency'. Despite payments to specified persons u/s 13(1)(c), the Revenue had allowed exemption in earlier years without adverse remarks. Applying Radhasoami Satsang, the ITAT ruled that without a change in facts or the earlier order being arbitrary/perverse, the Revenue cannot deviate from its consistent stance in subsequent years. Certainty and finality are essential, mandating consistent treatment unless material differences exist. The DR failed to demonstrate any infirmity or factual changes, leading to the decision against the Revenue.
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