Payments of accumulated charitable income to another registered...

Payments of accumulated charitable income to another registered institution were treated as taxable under the deeming rule because the source of funds was accumulation and the recipient held charitable registration; the nomenclature of the transfer as project expenditure or implementation charges did not matter. The rectification under mistake apparent from record was upheld because the relevant facts were already on the assessment record and no fresh inquiry was needed, so the issue was not a debatable one or a review. A challenge based on denial of a video conference hearing in faceless appellate proceedings also failed for want of shown prejudice. Consequential interest was held mandatory and subject only to recomputation.