Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Charitable purpose is not defeated where sponsorship receipts from a women's marathon have a real and proximate nexus with objects of women's health, fitness, awareness and empowerment. The proviso to section 2(15) requires proof that the recipient's activity intrinsically operates as trade, commerce or business; sponsors' advertising treatment, receipt magnitude or surplus alone is insufficient. The 20% receipts formulation did not apply for the relevant assessment year, and exceeding the applicable monetary threshold could not replace that proof. Consequently, section 13(8) could not deny exemption under sections 11 and 12. Form No. 10B furnished during assessment cured an erroneous original exemption form where audit was completed before return filing and eligibility was examined on merits; the lapse was procedural.
Charitable purpose is not defeated where sponsorship receipts from a women's marathon have a real and proximate nexus with objects of women's health, fitness, awareness and empowerment. The proviso to section 2(15) requires proof that the recipient's activity intrinsically operates as trade, commerce or business; sponsors' advertising treatment, receipt magnitude or surplus alone is insufficient. The 20% receipts formulation did not apply for the relevant assessment year, and exceeding the applicable monetary threshold could not replace that proof. Consequently, section 13(8) could not deny exemption under sections 11 and 12. Form No. 10B furnished during assessment cured an erroneous original exemption form where audit was completed before return filing and eligibility was examined on merits; the lapse was procedural.
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