Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
A trust's publication and natural dyeing activities did not negate approval where they were intrinsically linked to its objects of livelihood, skill development, training and employment for disadvantaged rural women, artisans and marginalised communities. The Tribunal held that generation of receipts alone did not show a profit motive, especially where expenditure on wages was substantial and income did not exceed expenditure in some years. It also noted the trust's genuineness, existing registration and absence of any diversion of funds or private benefit. The rejection of approval under section 80G(5) was set aside and approval was directed to be granted.
A trust's publication and natural dyeing activities did not negate approval where they were intrinsically linked to its objects of livelihood, skill development, training and employment for disadvantaged rural women, artisans and marginalised communities. The Tribunal held that generation of receipts alone did not show a profit motive, especially where expenditure on wages was substantial and income did not exceed expenditure in some years. It also noted the trust's genuineness, existing registration and absence of any diversion of funds or private benefit. The rejection of approval under section 80G(5) was set aside and approval was directed to be granted.
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