Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
Public servant status under anti-corruption law extends to recognised stock exchange leadership; constitutional and sanction challenges do not succeed...
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Section 12AA(2) of the Income Tax Act, 1961 does not recognize any deemed grant of registration if the application is not decided within six months. The Supreme Court in Harshit Foundation Sehmalpur upheld the Allahabad High Court's decision in Muzaffar Nagar Development Authority, which held that the Parliament has not provided for such a deeming fiction. This decision is the law declared by the Supreme Court under Article 141 of the Constitution. The decisions in Society for Promotion of Education and Harshit Foundation Sehmalpur are not mutually irreconcilable, as they address different aspects of the interplay between Sections 12A and 12AA(2). The specific deeming provision in Section 12AA(2) does not conceive any deemed registration if the application is not decided within six months.
Section 12AA(2) of the Income Tax Act, 1961 does not recognize any deemed grant of registration if the application is not decided within six months. The Supreme Court in Harshit Foundation Sehmalpur upheld the Allahabad High Court's decision in Muzaffar Nagar Development Authority, which held that the Parliament has not provided for such a deeming fiction. This decision is the law declared by the Supreme Court under Article 141 of the Constitution. The decisions in Society for Promotion of Education and Harshit Foundation Sehmalpur are not mutually irreconcilable, as they address different aspects of the interplay between Sections 12A and 12AA(2). The specific deeming provision in Section 12AA(2) does not conceive any deemed registration if the application is not decided within six months.
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