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...
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Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
ITAT determined that a registered charitable trust's income should be taxed at normal rates rather than maximum marginal rates, despite undefined trustee shares. While Sec 167B(1) mandates maximum marginal rates for associations of persons or bodies with indeterminate member shares, this applies only to non-company and non-cooperative society entities. The tribunal held that registered charitable trusts engaged in charitable activities per trust deed constitute a distinct category warranting normal tax treatment. The CIT(A)'s order was set aside, directing revenue authorities to recalculate tax liability using normal rates, providing relief to the appellant trust.
ITAT determined that a registered charitable trust's income should be taxed at normal rates rather than maximum marginal rates, despite undefined trustee shares. While Sec 167B(1) mandates maximum marginal rates for associations of persons or bodies with indeterminate member shares, this applies only to non-company and non-cooperative society entities. The tribunal held that registered charitable trusts engaged in charitable activities per trust deed constitute a distinct category warranting normal tax treatment. The CIT(A)'s order was set aside, directing revenue authorities to recalculate tax liability using normal rates, providing relief to the appellant trust.
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