Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
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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