Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Transfer of sale proceeds by a registered charitable trust to other charitable societies constitutes application of income for charitable purposes, and such inter trust donations do not justify cancellation or denial of registration under the tax regime. Relying on precedent, the tribunal affirmed that unsupported allegations about the donees do not vitiate donations and the trust's registration remains operative; accordingly, the trust retains entitlement to exemptions under sections governing charitable institutions and the Revenue's appeal was dismissed.
Transfer of sale proceeds by a registered charitable trust to other charitable societies constitutes application of income for charitable purposes, and such inter trust donations do not justify cancellation or denial of registration under the tax regime. Relying on precedent, the tribunal affirmed that unsupported allegations about the donees do not vitiate donations and the trust's registration remains operative; accordingly, the trust retains entitlement to exemptions under sections governing charitable institutions and the Revenue's appeal was dismissed.
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