Charitable registration turns on predominant purpose and genuine activities, while incidental fees and related-party rent require supporting adverse m...
MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory c...
Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
Preventive suspension requires an immediate continuing threat and cannot become indefinite without inquiry, fresh evidence, or proportionate safeguard...
Government salary grant received by a charitable trust under a binding condition for use only in salary payments was treated as a tied-up receipt and excluded from the income base for accumulation under section 11(1)(a). The Tribunal held that accumulation is available only in respect of income held under trust that is at the assessee's disposal and capable of being applied or set apart at its discretion; here, the trust acted merely as a conduit without dominion or beneficial control. The Bombay HC ruling in CIT v. Gem & Jewellery Export Promotion Council was distinguished because it concerned characterisation of grants as income, not their inclusion in the accumulation base.
Government salary grant received by a charitable trust under a binding condition for use only in salary payments was treated as a tied-up receipt and excluded from the income base for accumulation under section 11(1)(a). The Tribunal held that accumulation is available only in respect of income held under trust that is at the assessee's disposal and capable of being applied or set apart at its discretion; here, the trust acted merely as a conduit without dominion or beneficial control. The Bombay HC ruling in CIT v. Gem & Jewellery Export Promotion Council was distinguished because it concerned characterisation of grants as income, not their inclusion in the accumulation base.
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