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 ...
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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