Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
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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