Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
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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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