Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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