Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Charitable status under section 2(15) turned on the manner of application of income read with the stated objects in the memorandum of association. The High Court found no rational basis to treat the deployment of ex-servicemen as security guards as a separate business activity, since the Commissioner had accepted the other income-generating activities as aligned with the main objects. Concurrent findings also showed a low net profit ratio and that the activity was directed to the upliftment of ex-servicemen and their families, with only limited retention for administrative expenses. The Tribunal's conclusion that the institution was charitable and entitled to registration was therefore left undisturbed, and the appeal was dismissed.
Charitable status under section 2(15) turned on the manner of application of income read with the stated objects in the memorandum of association. The High Court found no rational basis to treat the deployment of ex-servicemen as security guards as a separate business activity, since the Commissioner had accepted the other income-generating activities as aligned with the main objects. Concurrent findings also showed a low net profit ratio and that the activity was directed to the upliftment of ex-servicemen and their families, with only limited retention for administrative expenses. The Tribunal's conclusion that the institution was charitable and entitled to registration was therefore left undisturbed, and the appeal was dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
