Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
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.