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 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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