Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
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The case concerns the cancellation of registration u/ss 12AA and 12AB of the Act, with a focus on the retrospective application of Section 12AB(4)(ii) introduced by the Finance Act, 2022. The Central CIT cancelled registration retroactively, citing this provision effective from 1.4.2022. However, the ITAT held that tax laws apply based on the year of assessment unless stated otherwise. Retroactive cancellation u/s 12AB(4)(ii) is invalid without explicit retrospective intent. Precedents like Auro Lab Ltd and Heart Foundation of India support this view, emphasizing that cancellation cannot apply retroactively. Consequently, the ITAT allowed the appeals of the assessee in these cases.
The case concerns the cancellation of registration u/ss 12AA and 12AB of the Act, with a focus on the retrospective application of Section 12AB(4)(ii) introduced by the Finance Act, 2022. The Central CIT cancelled registration retroactively, citing this provision effective from 1.4.2022. However, the ITAT held that tax laws apply based on the year of assessment unless stated otherwise. Retroactive cancellation u/s 12AB(4)(ii) is invalid without explicit retrospective intent. Precedents like Auro Lab Ltd and Heart Foundation of India support this view, emphasizing that cancellation cannot apply retroactively. Consequently, the ITAT allowed the appeals of the assessee in these cases.
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