Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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The ITAT set aside the rejection of the registration application under section 12AB, finding that the discrepancies in the dissolution clause and allegations of benefiting a particular community and non-genuineness of activities were curable defects. The assessee had modified the trust deed but failed to produce complete documentation before the CIT(E). Given the trust's longstanding recognition as a charitable entity under sections 11 and 12, the Tribunal granted the assessee an opportunity to rectify deficiencies and submit requisite evidence. The appeal was disposed of for statistical purposes, allowing the assessee to reapply with complete records to substantiate its charitable status and compliance with statutory requirements.
The ITAT set aside the rejection of the registration application under section 12AB, finding that the discrepancies in the dissolution clause and allegations of benefiting a particular community and non-genuineness of activities were curable defects. The assessee had modified the trust deed but failed to produce complete documentation before the CIT(E). Given the trust's longstanding recognition as a charitable entity under sections 11 and 12, the Tribunal granted the assessee an opportunity to rectify deficiencies and submit requisite evidence. The appeal was disposed of for statistical purposes, allowing the assessee to reapply with complete records to substantiate its charitable status and compliance with statutory requirements.
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