Writ relief against show cause notices is available where jurisdiction is absent and concluded advance rulings cannot be reopened without fresh fraud ...
Section 80P business attribution: ITAT allows deduction on investment interest and ancillary receipts, but excludes staff-loan and other non-eligible ...
Educational trust exemption was sustained despite allegations that development fee collections and surplus indicated capitation fee or profit motive, because the prior year's finding that the assessee was charitable and engaged in education had already been affirmed, and no fresh distinguishing material or proved violation of the capitation fee law was shown. Depreciation on trust assets remained allowable for A.Y. 2014-15, since section 11(6) operates prospectively from A.Y. 2015-16 and depreciation is part of real income computation; the disallowance failed. Capital gains exemption under section 11(1A) was also allowed on compulsory acquisition proceeds, as reinvestment in new capital assets is tested on substance and does not require strict fund-to-fund tracing, with proportionate relief available.
Educational trust exemption was sustained despite allegations that development fee collections and surplus indicated capitation fee or profit motive, because the prior year's finding that the assessee was charitable and engaged in education had already been affirmed, and no fresh distinguishing material or proved violation of the capitation fee law was shown. Depreciation on trust assets remained allowable for A.Y. 2014-15, since section 11(6) operates prospectively from A.Y. 2015-16 and depreciation is part of real income computation; the disallowance failed. Capital gains exemption under section 11(1A) was also allowed on compulsory acquisition proceeds, as reinvestment in new capital assets is tested on substance and does not require strict fund-to-fund tracing, with proportionate relief available.
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