Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Non-commencement of charitable activity at the time of applying for registration does not, by itself, constitute a specified violation; authorities must assess the charitable nature of objects and the genuineness of proposed activities, considering evidence of proposed and subsequent conduct. Inadvertent omissions in application forms and the existence of unsecured inter-trust loans are not conclusive proof of non-genuineness where financial statements show assets and liquidity constraints; such matters require further inquiry. Identical reasoning applies to approval for donor tax benefits, leaving assessment-stage verification of exemption claims open.
Non-commencement of charitable activity at the time of applying for registration does not, by itself, constitute a specified violation; authorities must assess the charitable nature of objects and the genuineness of proposed activities, considering evidence of proposed and subsequent conduct. Inadvertent omissions in application forms and the existence of unsecured inter-trust loans are not conclusive proof of non-genuineness where financial statements show assets and liquidity constraints; such matters require further inquiry. Identical reasoning applies to approval for donor tax benefits, leaving assessment-stage verification of exemption claims open.
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