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...
At the stage of registration under section 12AB, the enquiry is confined to whether the trust's objects are charitable, its activities are genuine, and any applicable law material to those objects has been complied with. Alleged benefits to members, related-party dealings, loans, or rent variations falling within section 13 are matters for assessment while considering exemption under sections 11 and 12, and do not by themselves justify refusal of registration. Section 12AB(4) applies only after registration and on specified violations. As there was no finding of non-charitable objects, ingenuine activities, false information, or final legal violation, the refusal was set aside and registration was directed to be granted.
At the stage of registration under section 12AB, the enquiry is confined to whether the trust's objects are charitable, its activities are genuine, and any applicable law material to those objects has been complied with. Alleged benefits to members, related-party dealings, loans, or rent variations falling within section 13 are matters for assessment while considering exemption under sections 11 and 12, and do not by themselves justify refusal of registration. Section 12AB(4) applies only after registration and on specified violations. As there was no finding of non-charitable objects, ingenuine activities, false information, or final legal violation, the refusal was set aside and registration was directed to be granted.
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