Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
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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