Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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ITAT reversed PCIT's cancellation of charitable trust registration under sections 12A and 12AB. The tribunal held that PCIT lacked express statutory authority to cancel section 12A registration through 12AB(4) proceedings. Show cause notices dated 21.07.2023 and 20.03.2024 were declared void ab initio. ITAT found that alleged 'specified violations' from FY 2019-20 to 2021-22 could not be basis for cancellation as this provision was effective only from 01.04.2022. While seized documents suggested irregularities in salary payments and capitation fees, ITAT ruled that trust's genuine charitable activities in operating medical college and hospital warranted continuation of registration. Any specific financial discrepancies could be addressed during assessment rather than through registration cancellation. Registration under sections 12A and 12AB restored.
ITAT reversed PCIT's cancellation of charitable trust registration under sections 12A and 12AB. The tribunal held that PCIT lacked express statutory authority to cancel section 12A registration through 12AB(4) proceedings. Show cause notices dated 21.07.2023 and 20.03.2024 were declared void ab initio. ITAT found that alleged 'specified violations' from FY 2019-20 to 2021-22 could not be basis for cancellation as this provision was effective only from 01.04.2022. While seized documents suggested irregularities in salary payments and capitation fees, ITAT ruled that trust's genuine charitable activities in operating medical college and hospital warranted continuation of registration. Any specific financial discrepancies could be addressed during assessment rather than through registration cancellation. Registration under sections 12A and 12AB restored.
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