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...
The Appellate Tribunal addressed the rejection of an application for approval u/s 80G as time-barred. Provisional registration was introduced for newly formed trusts. The Tribunal interpreted the statutory provision to avoid absurdity, holding that the time limit for existing trusts to apply for regular registration is within six months of the expiry of provisional registration. They clarified that the provision "within six months of commencement of activities" applies to trusts not engaged in charitable activities at the time of provisional registration. The Tribunal found the applicant's registration application valid and maintainable as it was submitted within the allowed time. Additionally, since the applicant had applied for permanent registration before the expiry of provisional approval, the application was not time-barred. The appeal of the assessee was allowed.
The Appellate Tribunal addressed the rejection of an application for approval u/s 80G as time-barred. Provisional registration was introduced for newly formed trusts. The Tribunal interpreted the statutory provision to avoid absurdity, holding that the time limit for existing trusts to apply for regular registration is within six months of the expiry of provisional registration. They clarified that the provision "within six months of commencement of activities" applies to trusts not engaged in charitable activities at the time of provisional registration. The Tribunal found the applicant's registration application valid and maintainable as it was submitted within the allowed time. Additionally, since the applicant had applied for permanent registration before the expiry of provisional approval, the application was not time-barred. The appeal of the assessee was allowed.
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