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...
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Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
ITAT allowed the assessee trust's appeal for statistical purposes, remanding the matter back to CIT(E) for reconsideration of 12AB registration. The tribunal found that operating a Dharmshala since 1962 should not automatically disqualify the trust from charitable status. The appellant was granted an opportunity to contest the original rejection of registration by presenting additional evidence and arguments regarding the nature of its activities, with the tribunal recognizing that running a Dharmshala does not inherently constitute commercial activity.
ITAT allowed the assessee trust's appeal for statistical purposes, remanding the matter back to CIT(E) for reconsideration of 12AB registration. The tribunal found that operating a Dharmshala since 1962 should not automatically disqualify the trust from charitable status. The appellant was granted an opportunity to contest the original rejection of registration by presenting additional evidence and arguments regarding the nature of its activities, with the tribunal recognizing that running a Dharmshala does not inherently constitute commercial activity.
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