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...
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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