Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
ITAT allowed the appeal regarding utilization of accumulated charitable funds under Section 11(3). The assessee accumulated funds in FY 2016-17 and utilized Rs. 2,32,073 during the additional one-year period in FY 2022-23, claiming deduction for AY 2023-24. CPC disallowed the claim citing Finance Act 2022 amendment removing the additional year provision effective 01.04.2023. ITAT held that applying the amendment retrospectively would create an impossible situation under the doctrine of impossibility (lex non cogit ad inpossibilia), as the assessee would be left with no time to utilize accumulated funds. The amendment cannot be interpreted to make fund utilization impossible within the originally provided timeframe. Legal obligations must be interpreted with practicality and reasonableness considering specific circumstances. The adjustment made during return processing was deleted.
ITAT allowed the appeal regarding utilization of accumulated charitable funds under Section 11(3). The assessee accumulated funds in FY 2016-17 and utilized Rs. 2,32,073 during the additional one-year period in FY 2022-23, claiming deduction for AY 2023-24. CPC disallowed the claim citing Finance Act 2022 amendment removing the additional year provision effective 01.04.2023. ITAT held that applying the amendment retrospectively would create an impossible situation under the doctrine of impossibility (lex non cogit ad inpossibilia), as the assessee would be left with no time to utilize accumulated funds. The amendment cannot be interpreted to make fund utilization impossible within the originally provided timeframe. Legal obligations must be interpreted with practicality and reasonableness considering specific circumstances. The adjustment made during return processing was deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
