Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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The ITAT allowed the appellant's appeal for statistical purposes and remitted the matter to the CIT(E) with directions to admit and consider the additional evidence after affording the appellant an opportunity of hearing and decide the question of registration under s.12AA and allegations under s.13(1)(c) in accordance with law. The Tribunal held that the trust's objects could constitute benefit to the public (a cross-section) rather than to only its members, rejected the characterisation of the activities as inherently commercial given minimal volume, no fees and use of institutional infrastructure, and found that conclusions of non-genuineness were not warranted on the record.
The ITAT allowed the appellant's appeal for statistical purposes and remitted the matter to the CIT(E) with directions to admit and consider the additional evidence after affording the appellant an opportunity of hearing and decide the question of registration under s.12AA and allegations under s.13(1)(c) in accordance with law. The Tribunal held that the trust's objects could constitute benefit to the public (a cross-section) rather than to only its members, rejected the characterisation of the activities as inherently commercial given minimal volume, no fees and use of institutional infrastructure, and found that conclusions of non-genuineness were not warranted on the record.
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