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...
ITAT held that at the stage of registration under section 12AB, enquiry is confined to the trust's objects and the genuineness of its activities, while issues of income application belong to assessment. It found the trust's procurement, processing and sale of rejected agricultural produce were intrinsically connected with relief of the poor and environmental protection, with surplus reinvested in charitable work. The tribunal rejected the view that purchase-sale accounts, salary , or CSR-funded receipts made the activity commercial, applying the predominant object test and noting no evidence of private profit. It set aside the rejection and directed grant of registration.
ITAT held that at the stage of registration under section 12AB, enquiry is confined to the trust's objects and the genuineness of its activities, while issues of income application belong to assessment. It found the trust's procurement, processing and sale of rejected agricultural produce were intrinsically connected with relief of the poor and environmental protection, with surplus reinvested in charitable work. The tribunal rejected the view that purchase-sale accounts, salary , or CSR-funded receipts made the activity commercial, applying the predominant object test and noting no evidence of private profit. It set aside the rejection and directed grant of registration.
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