Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
ITAT held that reference to a defined community in a trust's activities does not, by itself, negate charitable status where the overall objects and activities also benefit the general public. The Tribunal accepted that benefit to a limited class can still fall within public charity when the charitable purpose is not confined exclusively to that group. On that basis, the finding of specified violation under the Explanation to section 12AB(4) and the consequent cancellation of registration could not be sustained. The rejection and cancellation of registration were set aside and the appeal was allowed.
ITAT held that reference to a defined community in a trust's activities does not, by itself, negate charitable status where the overall objects and activities also benefit the general public. The Tribunal accepted that benefit to a limited class can still fall within public charity when the charitable purpose is not confined exclusively to that group. On that basis, the finding of specified violation under the Explanation to section 12AB(4) and the consequent cancellation of registration could not be sustained. The rejection and cancellation of registration were set aside and the appeal was allowed.
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