Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
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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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