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 non-grant of registration u/s 12AB from the assessment year 2021-22 due to an amendment to Clause (ac) of section 12A(1) by TOLA. The Tribunal found that the trust had applied for fresh registration in Form 10A as required by the amended law. It criticized the decision of the PCIT/CIT for granting registration only from 2022-23 to 2026-27 instead of from 2021-22 onwards. The Tribunal held that the assessee was entitled to registration from 2021-22, overturned the previous decision, and instructed the PCIT/CIT to grant registration from the said year. The appeal by the assessee was allowed for statistical purposes.
The Appellate Tribunal addressed the issue of non-grant of registration u/s 12AB from the assessment year 2021-22 due to an amendment to Clause (ac) of section 12A(1) by TOLA. The Tribunal found that the trust had applied for fresh registration in Form 10A as required by the amended law. It criticized the decision of the PCIT/CIT for granting registration only from 2022-23 to 2026-27 instead of from 2021-22 onwards. The Tribunal held that the assessee was entitled to registration from 2021-22, overturned the previous decision, and instructed the PCIT/CIT to grant registration from the said year. The appeal by the assessee was allowed for statistical purposes.
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