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...
Absence of an express irrevocability or dissolution clause in a trust instrument does not render a public charitable trust revocable; the legal principle is that irrevocability arises by operation of law unless the instrument reserves an express power of revocation, and section 12AB does not mandate an explicit irrevocability clause for registration or renewal. A departmental online utility that compels a 'Yes' response in Form 10AB cannot be treated as furnishing false information; compelled answers must not be grounds for rejection, the utility and question wording must be amended, and affected applications redetermined accordingly.
Absence of an express irrevocability or dissolution clause in a trust instrument does not render a public charitable trust revocable; the legal principle is that irrevocability arises by operation of law unless the instrument reserves an express power of revocation, and section 12AB does not mandate an explicit irrevocability clause for registration or renewal. A departmental online utility that compels a 'Yes' response in Form 10AB cannot be treated as furnishing false information; compelled answers must not be grounds for rejection, the utility and question wording must be amended, and affected applications redetermined accordingly.
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