Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
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Applicant seeking approval u/s 80G(5)(vi) - religious activities - it is clear that the CIT (E) has denied registration only on one ground violation of clause (iii) of sub-section (5) of Section 80G. The revenue cannot be allowed to make a new case. Even if we see that the ld counsel of the appellant has not contended that the Trust’s activities are centralised to only a few objects cannot be a ground for denying registration u/s.80G of the Act as this is not required to conduct activities on all the objects to get approval & registration u/s.80G and it is also not a requirement of section 80G of the Act to conduct activities on all the objects stated in the Trust Deed. - AT
Applicant seeking approval u/s 80G(5)(vi) - religious activities - it is clear that the CIT (E) has denied registration only on one ground violation of clause (iii) of sub-section (5) of Section 80G. The revenue cannot be allowed to make a new case. Even if we see that the ld counsel of the appellant has not contended that the Trust’s activities are centralised to only a few objects cannot be a ground for denying registration u/s.80G of the Act as this is not required to conduct activities on all the objects to get approval & registration u/s.80G and it is also not a requirement of section 80G of the Act to conduct activities on all the objects stated in the Trust Deed. - AT
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