Compulsorily convertible debentures remain debt before conversion, preventing transfer-pricing and interest-deduction disallowances on the stated fact...
Stock-in-trade transfer taxability follows possession and consideration, not later conveyance registration, limiting deemed-value provisions to the ac...
Alternative statutory remedy under GST bars writ challenge where classification, notice variance, and hearing disputes require factual appellate revie...
The Appellate Tribunal addressed the issue of exemption u/s 11 for income from property held for charitable purposes. It held that the provision of section 11(1)(a) applies, limiting the allowance to 15% of the income from trust property if no application of income is made for charitable purposes. The Tribunal clarified that in the absence of the assessee exercising the option to accumulate income, 85% of the income must be applied for charitable purposes. The Tribunal rejected the Revenue's adjustment u/s 143(1)(a) and assessed the income at Rs. 87,430. It also discussed the incorrect application of section 167B for tax rate computation, stating that it should follow normal rates for Associations of Persons. The Tribunal allowed the assessee's appeal.
The Appellate Tribunal addressed the issue of exemption u/s 11 for income from property held for charitable purposes. It held that the provision of section 11(1)(a) applies, limiting the allowance to 15% of the income from trust property if no application of income is made for charitable purposes. The Tribunal clarified that in the absence of the assessee exercising the option to accumulate income, 85% of the income must be applied for charitable purposes. The Tribunal rejected the Revenue's adjustment u/s 143(1)(a) and assessed the income at Rs. 87,430. It also discussed the incorrect application of section 167B for tax rate computation, stating that it should follow normal rates for Associations of Persons. The Tribunal allowed the assessee's appeal.
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