Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Denial of exemption u/s 11 by the CPC u/s 143(1) due to non-furnishing of fresh registration u/s 12AB was challenged. The assessee had provisional registration u/s 12AB but failed to upload Form 10B within the prescribed time. The ITAT held that the assessee's existing registration u/s 12AA protected their claim for exemption u/s 11 until the assessment year 2021-22. The fresh registration u/s 12AB granted for assessment years 2022-23 to 2026-27 made the assessee eligible for exemption u/s 11. The grounds raised by the assessee were allowed.
Denial of exemption u/s 11 by the CPC u/s 143(1) due to non-furnishing of fresh registration u/s 12AB was challenged. The assessee had provisional registration u/s 12AB but failed to upload Form 10B within the prescribed time. The ITAT held that the assessee's existing registration u/s 12AA protected their claim for exemption u/s 11 until the assessment year 2021-22. The fresh registration u/s 12AB granted for assessment years 2022-23 to 2026-27 made the assessee eligible for exemption u/s 11. The grounds raised by the assessee were allowed.
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