Transfer-pricing aggregation of distinct support-service and subcontract transactions was rejected, while debt-free receivables attracted no notional ...
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ITAT allowed the appeal filed by the assessee-trust, holding that the earlier dismissal was based on a patent mistake in applying s.12AA. ITAT observed that the assessee already held a valid registration under s.12AA at the time of filing the return for the relevant assessment year, and the amended registration regime, effective from 01.04.2021, was inapplicable to that year. Further, the assessee had subsequently obtained registration under the amended provisions on 28.03.2022, reinforcing its eligible status. ITAT held that CIT(A) erred in dismissing the appeal for non-furnishing of a new registration number and misapplication of amended law. Consequently, ITAT directed the AO to delete the demand raised by CPC, thereby granting full relief to the assessee.
ITAT allowed the appeal filed by the assessee-trust, holding that the earlier dismissal was based on a patent mistake in applying s.12AA. ITAT observed that the assessee already held a valid registration under s.12AA at the time of filing the return for the relevant assessment year, and the amended registration regime, effective from 01.04.2021, was inapplicable to that year. Further, the assessee had subsequently obtained registration under the amended provisions on 28.03.2022, reinforcing its eligible status. ITAT held that CIT(A) erred in dismissing the appeal for non-furnishing of a new registration number and misapplication of amended law. Consequently, ITAT directed the AO to delete the demand raised by CPC, thereby granting full relief to the assessee.
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