Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
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Exemption u/s 11 - deemed grant of registration - The period of six months referred in Section 12AA(2) has to be calculated from the end of the months in which the application u/s 12A was received and not from any other date. - Tribunal was not justified in applying Section 12AA(2) of the Act, 1961 in the facts of the present case and the order of CIT could not have been set aside on this ground. The decision of the Tribunal is based on a misreading and misunderstanding of Section 12AA(2) of the Act, 1961, its purport and scope. - HC
Exemption u/s 11 - deemed grant of registration - The period of six months referred in Section 12AA(2) has to be calculated from the end of the months in which the application u/s 12A was received and not from any other date. - Tribunal was not justified in applying Section 12AA(2) of the Act, 1961 in the facts of the present case and the order of CIT could not have been set aside on this ground. The decision of the Tribunal is based on a misreading and misunderstanding of Section 12AA(2) of the Act, 1961, its purport and scope. - HC
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