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...
Royalty and sponsorship receipts received by a sports federation were held to be incidental to its charitable objects and not indicative of any business activity or profit motive. As the facts for the year matched the assessee's earlier case, the Tribunal followed that precedent and held that the proviso to section 2(15) did not apply. Exemption under sections 11 and 12 was therefore sustained, the Revenue's challenge failed, and the assessee's cross-objection was dismissed as infructuous.
Royalty and sponsorship receipts received by a sports federation were held to be incidental to its charitable objects and not indicative of any business activity or profit motive. As the facts for the year matched the assessee's earlier case, the Tribunal followed that precedent and held that the proviso to section 2(15) did not apply. Exemption under sections 11 and 12 was therefore sustained, the Revenue's challenge failed, and the assessee's cross-objection was dismissed as infructuous.
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