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...
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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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