Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
Specified development authority income receives retrospective tax exemption, subject to non-commercial activity, unchanged income sources, and return-...
Unified Brand India framework introduces voluntary Trust Mark certification and funding support for export branding, packaging and global promotional ...
Origin Declaration authentication governs preferential tariff claims under India-UK CETA, requiring a validated reference number before import clearan...
Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
Reopening of assessment - income arising from the revocable transfer of assets - taxability in the hands of trust or transferor/settler - The Appellate Tribunal observed that the trust was indeed revocable. - It was noted that the income from the purchase of mutual funds had already been offered to tax in the return of income filed by the settlor, as per Section 61 of the Act. - The Tribunal reiterated the provision of Section 61, stating that income arising from a revocable transfer of assets is taxable in the hands of the transferor, i.e., the settlor of the trust. The trust deed itself indicated that any income or source of investment in mutual funds was to be taxable in the hands of the settlor. - The ITAT found the actions of the authorities arbitrary and emphasized that the income had already been offered by the settlor, hence taxing it again in the hands of the trust was unjustified.
Reopening of assessment - income arising from the revocable transfer of assets - taxability in the hands of trust or transferor/settler - The Appellate Tribunal observed that the trust was indeed revocable. - It was noted that the income from the purchase of mutual funds had already been offered to tax in the return of income filed by the settlor, as per Section 61 of the Act. - The Tribunal reiterated the provision of Section 61, stating that income arising from a revocable transfer of assets is taxable in the hands of the transferor, i.e., the settlor of the trust. The trust deed itself indicated that any income or source of investment in mutual funds was to be taxable in the hands of the settlor. - The ITAT found the actions of the authorities arbitrary and emphasized that the income had already been offered by the settlor, hence taxing it again in the hands of the trust was unjustified.
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