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...
The case pertains to the refusal of registration u/s 12AA for charitable activities u/s 2(15). The Commissioner of Income Tax observed that the society was not imparting education as a charitable purpose within the meaning of Section 2(15), despite being granted approval u/s 10(23)(vi). The court held that the powers to cancel registration u/s 12AA(3) can only be applied prospectively, not retrospectively, as per precedents. Since the institute is a registered educational trust and utilizes earnings for education, it cannot be denied registration u/s 12AA. The High Court dismissed the appeal, finding no error by the Income Tax Appellate Tribunal in granting registration u/s 12AA.
The case pertains to the refusal of registration u/s 12AA for charitable activities u/s 2(15). The Commissioner of Income Tax observed that the society was not imparting education as a charitable purpose within the meaning of Section 2(15), despite being granted approval u/s 10(23)(vi). The court held that the powers to cancel registration u/s 12AA(3) can only be applied prospectively, not retrospectively, as per precedents. Since the institute is a registered educational trust and utilizes earnings for education, it cannot be denied registration u/s 12AA. The High Court dismissed the appeal, finding no error by the Income Tax Appellate Tribunal in granting registration u/s 12AA.
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