Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
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The Appellate Tribunal addressed the rejection of registration application u/s 12A/12AB due to a clerical error in selecting the appropriate section in the e-filing portal. The Tribunal found the error to be inadvertent and allowed correction in the application. The Tribunal directed the authority to consider the application under the correct sub-clause of section 12A(1) and to assess the case on merit. The delay in filing the application for approval u/s 80G(5) was also addressed, citing a recent CBDT circular extending the deadline. The Tribunal granted the assessee the benefit of the extended period for filing the application. The appeal was allowed for statistical purposes.
The Appellate Tribunal addressed the rejection of registration application u/s 12A/12AB due to a clerical error in selecting the appropriate section in the e-filing portal. The Tribunal found the error to be inadvertent and allowed correction in the application. The Tribunal directed the authority to consider the application under the correct sub-clause of section 12A(1) and to assess the case on merit. The delay in filing the application for approval u/s 80G(5) was also addressed, citing a recent CBDT circular extending the deadline. The Tribunal granted the assessee the benefit of the extended period for filing the application. The appeal was allowed for statistical purposes.
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