Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Time limit to file application u/s 80G(5) - assessment of trust - The tribunal interpreted the provisions in light of the Budget Speech of the Hon’ble Finance Minister 2020, highlighting the intent behind the introduction of provisional registration to simplify compliance for new and existing charitable institutions. - The tribunal noted that the provisions allowed for provisional approval and subsequent regular registration. It reasoned that the time limit for application, specifically mentioned in clause (iii) of the proviso to Section 80G(5), was applicable to trusts or institutions commencing activities after provisional registration. However, for existing trusts or institutions engaged in charitable activities before provisional registration, the six-month time limit applied from the expiry of provisional registration.
Time limit to file application u/s 80G(5) - assessment of trust - The tribunal interpreted the provisions in light of the Budget Speech of the Hon’ble Finance Minister 2020, highlighting the intent behind the introduction of provisional registration to simplify compliance for new and existing charitable institutions. - The tribunal noted that the provisions allowed for provisional approval and subsequent regular registration. It reasoned that the time limit for application, specifically mentioned in clause (iii) of the proviso to Section 80G(5), was applicable to trusts or institutions commencing activities after provisional registration. However, for existing trusts or institutions engaged in charitable activities before provisional registration, the six-month time limit applied from the expiry of provisional registration.
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