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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...
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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, set aside the impugned order of the Commissioner and held the assessee's application for regular registration u/s 80G(5) to be within limitation. The Tribunal found the proviso's first clause-requiring filing six months prior to expiry of provisional approval-applicable because provisional registration extended to A.Y. 2025-26 and the application was filed on 30.09.2024; the second clause (six months from commencement of activities) was inapplicable to an entity which commenced activities in 1952. The matter is remitted to the Commissioner to treat the application as valid and decide merits afresh. Appeal allowed for statistical purposes.
ITAT allowed the appeal, set aside the impugned order of the Commissioner and held the assessee's application for regular registration u/s 80G(5) to be within limitation. The Tribunal found the proviso's first clause-requiring filing six months prior to expiry of provisional approval-applicable because provisional registration extended to A.Y. 2025-26 and the application was filed on 30.09.2024; the second clause (six months from commencement of activities) was inapplicable to an entity which commenced activities in 1952. The matter is remitted to the Commissioner to treat the application as valid and decide merits afresh. Appeal allowed for statistical purposes.
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