Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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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