Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
The first proviso to section 12A(2) extends the benefit of section 12AB registration to earlier assessment years where the trust's objects and activities remain unchanged and assessment proceedings are pending. Appeals against assessments are treated as a continuation of assessment proceedings and therefore as pending proceedings for this purpose. Where the trust satisfies the applicable income-application requirement, exemption under sections 11 to 13 may be available for those prior years. The stated application extends the registration benefit to the assessment year under appeal and substantially similar subsequent years, requiring deletion of related additions.
The first proviso to section 12A(2) extends the benefit of section 12AB registration to earlier assessment years where the trust's objects and activities remain unchanged and assessment proceedings are pending. Appeals against assessments are treated as a continuation of assessment proceedings and therefore as pending proceedings for this purpose. Where the trust satisfies the applicable income-application requirement, exemption under sections 11 to 13 may be available for those prior years. The stated application extends the registration benefit to the assessment year under appeal and substantially similar subsequent years, requiring deletion of related additions.
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