Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Registration under section 12AB could not be refused merely because a charitable trust was at an initial stage and had conducted only a medical conference. The Tribunal held that, for registration, the Commissioner must examine both the objects and the proposed activities of the trust. The deed showed charitable objects directed to medical relief, public awareness, treatment support, assistance to students, old age homes and allied public causes, and the asset-transfer clause on dissolution was inconsistent with a mutual concern. Limited commencement of activities was not, by itself, a disqualifying violation. The mutuality finding was therefore unsustainable, and the application was to be processed for registration.
Registration under section 12AB could not be refused merely because a charitable trust was at an initial stage and had conducted only a medical conference. The Tribunal held that, for registration, the Commissioner must examine both the objects and the proposed activities of the trust. The deed showed charitable objects directed to medical relief, public awareness, treatment support, assistance to students, old age homes and allied public causes, and the asset-transfer clause on dissolution was inconsistent with a mutual concern. Limited commencement of activities was not, by itself, a disqualifying violation. The mutuality finding was therefore unsustainable, and the application was to be processed for registration.
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