Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
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.
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