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Pre-commencement R&D deduction denied where business had not commenced; deeming benefit requires tangible start of manufacture or commercial exploitat...
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Section 13(1)(b) was held inapplicable where the institution was...
Charitable institution cannot lose exemption merely because some activities incidentally benefit a religious community; retrospective registration cancellation fails too.
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Section 13(1)(b) was held inapplicable where the institution was engaged in charitable activity and the Revenue relied only on an alleged incidental benefit to a particular religious community; the Tribunal deleted the additions for school construction and auto distribution expenses because the assessee was not shown to be created or established for that community. It also set aside retrospective cancellation of registration under the amended registration regime, holding that cancellation cannot be pushed back to earlier years absent express legislative authority, especially where the underlying section 13(1)(b) basis had already failed.
Section 13(1)(b) was held inapplicable where the institution was engaged in charitable activity and the Revenue relied only on an alleged incidental benefit to a particular religious community; the Tribunal deleted the additions for school construction and auto distribution expenses because the assessee was not shown to be created or established for that community. It also set aside retrospective cancellation of registration under the amended registration regime, holding that cancellation cannot be pushed back to earlier years absent express legislative authority, especially where the underlying section 13(1)(b) basis had already failed.
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