Transfer-pricing aggregation of distinct support-service and subcontract transactions was rejected, while debt-free receivables attracted no notional ...
Customs exemptions cover photovoltaic assembly machinery and PVF backsheets, while fully declared cleared imports may avoid confiscation and penalties...
Specific tariff classification for LCD devices overrides treatment as electricity-meter parts, defeating differential duty, extended limitation, and p...
Stayed disciplinary punishment does not establish unfitness for insolvency professional registration; reconsideration must disregard mere pendency of ...
Indirect corporate control can create related-party status, excluding financial creditors from Committee of Creditors representation, participation an...
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ITAT allowed the appeal of the assessee, holding that the Finance Act, 2022 amendment removing the additional one-year post five-year utilisation window cannot be applied retrospectively to existing accumulations. Applying the doctrine lex non cogit ad impossibilia, the Tribunal found that retrospective application would render utilisation impossible and produce an absurd outcome. The Tribunal followed precedent treating the amendment as prospective for fresh accumulations from 1-4-2022, and upheld that accumulations arising in FY 2016-17 and FY 2017-18 remained governed by the pre-amendment six-year window (with deadlines of 31-3-2023 and 31-3-2024 respectively). Consequently, additions for those accumulations were deleted.
ITAT allowed the appeal of the assessee, holding that the Finance Act, 2022 amendment removing the additional one-year post five-year utilisation window cannot be applied retrospectively to existing accumulations. Applying the doctrine lex non cogit ad impossibilia, the Tribunal found that retrospective application would render utilisation impossible and produce an absurd outcome. The Tribunal followed precedent treating the amendment as prospective for fresh accumulations from 1-4-2022, and upheld that accumulations arising in FY 2016-17 and FY 2017-18 remained governed by the pre-amendment six-year window (with deadlines of 31-3-2023 and 31-3-2024 respectively). Consequently, additions for those accumulations were deleted.
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