Social forestry expenditure requires activity-based classification, limiting book-profit adjustments and preserving penalty relief where normal additi...
Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
Customs Broker due diligence requires prescribed KYC, not detecting misdeclarations discoverable only through physical examination, defeating licence ...
ITAT addressed registration denial under Section 12AB, focusing on Trust's eligibility for exemption under Section 11. Jurisdictional HC judgment in CIT(E) vs. Jamiatul Banaat Tankaria established that Section 13 provisions apply during assessment, not registration. For Trusts created before 01-04-2021, registration eligibility precedes Section 13(1)(b) applicability. ITAT allowed assessee's appeal, directing CIT (Exemption) to grant final registration under Section 12AB after providing hearing opportunity, effectively reinstating Trust's registration status subject to subsequent assessment scrutiny.
ITAT addressed registration denial under Section 12AB, focusing on Trust's eligibility for exemption under Section 11. Jurisdictional HC judgment in CIT(E) vs. Jamiatul Banaat Tankaria established that Section 13 provisions apply during assessment, not registration. For Trusts created before 01-04-2021, registration eligibility precedes Section 13(1)(b) applicability. ITAT allowed assessee's appeal, directing CIT (Exemption) to grant final registration under Section 12AB after providing hearing opportunity, effectively reinstating Trust's registration status subject to subsequent assessment scrutiny.
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