Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Section 12AB(4) cancellation for specified violation is stated to operate prospectively from 01.04.2022, so a cancellation based on alleged breaches from FY 2014-15 was treated as retrospective application not permitted by the statute. The text further notes that reliance on section 12AA after its omission from 01.04.2021 was inconsistent with the statutory framework, and jurisdiction under section 12AB(4) could not arise without a specified violation after 01.04.2022. On merits, the alleged expenses were said to support religious and charitable objects, while valuation issues, accounting lapses and procedural defects did not establish non-genuineness or false information. The cancellation was therefore described as unsustainable.
Section 12AB(4) cancellation for specified violation is stated to operate prospectively from 01.04.2022, so a cancellation based on alleged breaches from FY 2014-15 was treated as retrospective application not permitted by the statute. The text further notes that reliance on section 12AA after its omission from 01.04.2021 was inconsistent with the statutory framework, and jurisdiction under section 12AB(4) could not arise without a specified violation after 01.04.2022. On merits, the alleged expenses were said to support religious and charitable objects, while valuation issues, accounting lapses and procedural defects did not establish non-genuineness or false information. The cancellation was therefore described as unsustainable.
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