Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
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Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
The ITAT allowed the appellant's appeal against CIT(E)'s rejection of registration under s.12AB. The Tribunal found that the trust deed contained objects for charitable activities to the general public, and the trust had provided education and healthcare to families of employees who died during the COVID-19 pandemic. The ITAT held that deceased employees' family members constitute "public" with no employer-employee relationship existing between them and the appellant. Regarding the absence of a dissolution clause, the Tribunal ruled that after the insertion of s.115TD by Finance Act 2016, concerns about transfer of net assets have been addressed, making this insufficient grounds to deny registration. The CIT(E) erred in rejecting registration under s.12A and s.80G.
The ITAT allowed the appellant's appeal against CIT(E)'s rejection of registration under s.12AB. The Tribunal found that the trust deed contained objects for charitable activities to the general public, and the trust had provided education and healthcare to families of employees who died during the COVID-19 pandemic. The ITAT held that deceased employees' family members constitute "public" with no employer-employee relationship existing between them and the appellant. Regarding the absence of a dissolution clause, the Tribunal ruled that after the insertion of s.115TD by Finance Act 2016, concerns about transfer of net assets have been addressed, making this insufficient grounds to deny registration. The CIT(E) erred in rejecting registration under s.12A and s.80G.
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