Effective service requirement: officers must explore alternative service modes beyond the GST portal and afford personal hearing; non-compliance voids...
Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
After insertion of Section 12A(2) and the corresponding amendment to Section 12AA(1), registration for charitable exemption under Sections 11 and 12 operates only from the assessment year immediately following the financial year in which the application is made. The earlier view permitting registration from the date of creation of the institution or another chosen date was displaced, and Section 12A registration was treated as a pre-condition with no independent retrospective effect for exemption claims. The proviso to Section 12A(2) did not apply because no relevant assessment proceedings were pending. The HC therefore set aside the Tribunal's order granting retrospective registration and upheld only prospective registration.
After insertion of Section 12A(2) and the corresponding amendment to Section 12AA(1), registration for charitable exemption under Sections 11 and 12 operates only from the assessment year immediately following the financial year in which the application is made. The earlier view permitting registration from the date of creation of the institution or another chosen date was displaced, and Section 12A registration was treated as a pre-condition with no independent retrospective effect for exemption claims. The proviso to Section 12A(2) did not apply because no relevant assessment proceedings were pending. The HC therefore set aside the Tribunal's order granting retrospective registration and upheld only prospective registration.
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