Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
Exemption under Section 10(23C)(iiiad) - Determination of threshold of turnover - ‘annual receipts’ versus ‘gross receipt’ - The Assessing Officer (AO) disallowed the claim, stating that the gross receipt of the college exceeded the threshold limit, thereby making it ineligible for exemption under this provision. - However, the Tribunal's decision highlighted that the provision refers to "annual receipts" and not "gross receipts." It argued that voluntary contributions towards corpus, which are uncertain as to time and volume, should not be considered part of the regular, annual receipt of an educational institution. - The Tribunal allowed the college's appeal, directing the deletion of the disallowance of exemption under Section 10(23C)(iiiad).
Exemption under Section 10(23C)(iiiad) - Determination of threshold of turnover - ‘annual receipts’ versus ‘gross receipt’ - The Assessing Officer (AO) disallowed the claim, stating that the gross receipt of the college exceeded the threshold limit, thereby making it ineligible for exemption under this provision. - However, the Tribunal's decision highlighted that the provision refers to "annual receipts" and not "gross receipts." It argued that voluntary contributions towards corpus, which are uncertain as to time and volume, should not be considered part of the regular, annual receipt of an educational institution. - The Tribunal allowed the college's appeal, directing the deletion of the disallowance of exemption under Section 10(23C)(iiiad).
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