Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
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For charitable income, Explanation 2(ii)(b) to section 11(1) operated as a mechanism distinct from accumulation under section 11(2): the assessee claimed only deemed application in the immediately succeeding year, not long-term accumulation. The Tribunal held that, for A.Y. 2015-16, a written option within the time allowed under section 139(1) was sufficient; the later Form No. 9A requirement could not be applied retrospectively. Disclosure in the return and furnishing of reasons before completion of assessment satisfied the statutory condition, so the disallowance of deemed application and the consequential denial of exemption were unsustainable.
For charitable income, Explanation 2(ii)(b) to section 11(1) operated as a mechanism distinct from accumulation under section 11(2): the assessee claimed only deemed application in the immediately succeeding year, not long-term accumulation. The Tribunal held that, for A.Y. 2015-16, a written option within the time allowed under section 139(1) was sufficient; the later Form No. 9A requirement could not be applied retrospectively. Disclosure in the return and furnishing of reasons before completion of assessment satisfied the statutory condition, so the disallowance of deemed application and the consequential denial of exemption were unsustainable.
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