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 ...
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Exemption u/s 11 - whether the objects of the trust were charitable? - The High court found that the issue of interpretation of Section 11 was covered by previous rulings and did not raise substantial questions of law. - As for the restriction of denial of benefit under Section 11, the court agreed with the respondent's argument, stating that only income used for the benefit of prohibited persons should be denied exemption. - Regarding the applicability of the Bharat Diamond Bourse case, the court clarified that it did not specify whether the denial of benefit under Section 11 should apply to the entire income or only to diverted funds. - The court admitted the question regarding the eligibility of expenditure incurred on new objects for exemption under Section 11 for further consideration.
Exemption u/s 11 - whether the objects of the trust were charitable? - The High court found that the issue of interpretation of Section 11 was covered by previous rulings and did not raise substantial questions of law. - As for the restriction of denial of benefit under Section 11, the court agreed with the respondent's argument, stating that only income used for the benefit of prohibited persons should be denied exemption. - Regarding the applicability of the Bharat Diamond Bourse case, the court clarified that it did not specify whether the denial of benefit under Section 11 should apply to the entire income or only to diverted funds. - The court admitted the question regarding the eligibility of expenditure incurred on new objects for exemption under Section 11 for further consideration.
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