Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Belated filing of Form 10B was treated as a procedural lapse that should not defeat exemption claims under sections 11 and 12 in the peculiar facts of the case. Relying on the principle that technical defaults should not override substantive entitlement, and following prior precedent, the Tribunal directed the Assessing Officer to treat the trust's Form 10B as filed within time and process the return accordingly. The appeal was thus allowed, with the delayed filing not being permitted to deny the claimed charitable exemption.
Belated filing of Form 10B was treated as a procedural lapse that should not defeat exemption claims under sections 11 and 12 in the peculiar facts of the case. Relying on the principle that technical defaults should not override substantive entitlement, and following prior precedent, the Tribunal directed the Assessing Officer to treat the trust's Form 10B as filed within time and process the return accordingly. The appeal was thus allowed, with the delayed filing not being permitted to deny the claimed charitable exemption.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4824 
Join Channel 
