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...
A public charitable trust is treated as irrevocable by operation of law unless the trust deed expressly reserves a power of revocation, so the absence of an explicit irrevocability or dissolution clause cannot by itself justify denial of registration or renewal under section 12AB. The Tribunal also held that answering "Yes" in row 6 of Form 10AB, despite the absence of such a clause, is not false or incorrect information and does not amount to a specified violation under Explanation (g) to section 12AB(4). As the section 12AB rejection could not stand, the consequential refusal of approval under section 80G also failed and both rejections were set aside.
A public charitable trust is treated as irrevocable by operation of law unless the trust deed expressly reserves a power of revocation, so the absence of an explicit irrevocability or dissolution clause cannot by itself justify denial of registration or renewal under section 12AB. The Tribunal also held that answering "Yes" in row 6 of Form 10AB, despite the absence of such a clause, is not false or incorrect information and does not amount to a specified violation under Explanation (g) to section 12AB(4). As the section 12AB rejection could not stand, the consequential refusal of approval under section 80G also failed and both rejections were set aside.
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