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...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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Approval u/s 80G(5)(iii) - time limit - The ITAT highlighted the distinction between applications for renewal and fresh registration, as well as the prescribed time limits for each. - The Tribunal concluded that the appellant's application for final approval was valid, despite having commenced activities before provisional registration. It clarified that the application could not be rejected solely on the grounds of the appellant's prior commencement of activities, as long as provisional registration had been granted. - It emphasized that the appellant's choice to apply for fresh provisional registration did not preclude them from subsequently applying for final approval.
Approval u/s 80G(5)(iii) - time limit - The ITAT highlighted the distinction between applications for renewal and fresh registration, as well as the prescribed time limits for each. - The Tribunal concluded that the appellant's application for final approval was valid, despite having commenced activities before provisional registration. It clarified that the application could not be rejected solely on the grounds of the appellant's prior commencement of activities, as long as provisional registration had been granted. - It emphasized that the appellant's choice to apply for fresh provisional registration did not preclude them from subsequently applying for final approval.
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