Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
The ITAT held that salary paid by a charitable trust to its Chairperson was not excessive where the Department had accepted similar remuneration in earlier and later years, so the disallowance under section 13(2)(c) was deleted. It also found that repairs to rented premises used by the trust were commercially expedient and that no personal benefit to a specified person had been shown, so that addition was deleted as well. On the separate appellate issue, the Tribunal held that the CIT(A) had failed to consider the assessee's written submissions, additional evidence and Rule 46A application, amounting to a natural justice defect, and remanded the matter for fresh adjudication after reasonable opportunity.
The ITAT held that salary paid by a charitable trust to its Chairperson was not excessive where the Department had accepted similar remuneration in earlier and later years, so the disallowance under section 13(2)(c) was deleted. It also found that repairs to rented premises used by the trust were commercially expedient and that no personal benefit to a specified person had been shown, so that addition was deleted as well. On the separate appellate issue, the Tribunal held that the CIT(A) had failed to consider the assessee's written submissions, additional evidence and Rule 46A application, amounting to a natural justice defect, and remanded the matter for fresh adjudication after reasonable opportunity.
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