Automated airline software subscriptions without human intervention fail technical-services characterisation and do not make available underlying tech...
Business support recruitment and training receipts qualify for presumptive business taxation, not professional taxation under technical consultancy ru...
Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
Centralised assessment transfers: participation after requesting centralisation can bar technical jurisdictional challenges, while assessment disputes...
Binding precedent remains operative despite pending challenge, supporting deletion of interest disallowance when debt is converted into preference sha...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4927 
