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...
Cancellation of registration granted u/s 12AB - Assessment of trust - The ITAT held that the PCIT's order to cancel the registration from the financial year 2020-21 and subsequent years under section 12AB(4)(ii) was beyond his jurisdiction, particularly for the assessment year 2021-22, as the provision was not applicable retrospectively. - The Tribunal clarified that the law applicable to an assessment year should be the law in force for that year unless specified otherwise.
Cancellation of registration granted u/s 12AB - Assessment of trust - The ITAT held that the PCIT's order to cancel the registration from the financial year 2020-21 and subsequent years under section 12AB(4)(ii) was beyond his jurisdiction, particularly for the assessment year 2021-22, as the provision was not applicable retrospectively. - The Tribunal clarified that the law applicable to an assessment year should be the law in force for that year unless specified otherwise.
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