Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
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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