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...
The Appellate Tribunal addressed the issue of rejection of approval u/s 80G due to late filing of Form 10AB. The Tribunal held that the CIT(E) should have considered the application on merits rather than declaring it non-maintainable solely based on the commencement date of activities. The assessee obtained provisional approval and filed Form 10AB within the specified time frame, meeting the requirements of Section 80G(5)(iii). The Tribunal emphasized that the commencement date of activities before incorporation was irrelevant in this case. The phrase "whichever is earlier" was deemed inapplicable given the unique circumstances of the case. The decision lacked a thorough examination of the merits of the application, highlighting a legal flaw in the approach taken.
The Appellate Tribunal addressed the issue of rejection of approval u/s 80G due to late filing of Form 10AB. The Tribunal held that the CIT(E) should have considered the application on merits rather than declaring it non-maintainable solely based on the commencement date of activities. The assessee obtained provisional approval and filed Form 10AB within the specified time frame, meeting the requirements of Section 80G(5)(iii). The Tribunal emphasized that the commencement date of activities before incorporation was irrelevant in this case. The phrase "whichever is earlier" was deemed inapplicable given the unique circumstances of the case. The decision lacked a thorough examination of the merits of the application, highlighting a legal flaw in the approach taken.
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