Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
ITAT held that accumulation of income validly made by a charitable trust in A.Y. 2017-18 could be applied in A.Y. 2023-24, because the law then permitted utilisation within five years and in the immediately succeeding year. The Finance Act, 2022 amendment to section 11(3) was treated as prospective and incapable of extinguishing an already accrued right of utilisation. The Tribunal also noted that the timing of the amendment left no practical opportunity to comply with the shortened period, and a law cannot require performance of an impossible act. The addition under section 11(3) was deleted and the Revenue's appeal was rejected.
ITAT held that accumulation of income validly made by a charitable trust in A.Y. 2017-18 could be applied in A.Y. 2023-24, because the law then permitted utilisation within five years and in the immediately succeeding year. The Finance Act, 2022 amendment to section 11(3) was treated as prospective and incapable of extinguishing an already accrued right of utilisation. The Tribunal also noted that the timing of the amendment left no practical opportunity to comply with the shortened period, and a law cannot require performance of an impossible act. The addition under section 11(3) was deleted and the Revenue's appeal was rejected.
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