Capital-gains exemption for charitable trusts extends to qualifying fixed deposits, while unrecoverable TDS write-offs may constitute income applicati...
India-UK treaty characterisation of telecom-service receipts as business profits withstands unilateral domestic-law amendments for Indian tax purposes...
Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
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The AO denied exemption u/s 11 to the assessee trust based on incriminating evidence of undisclosed income declared under PMGKY, systematic recovery of staff salaries, bogus corpus donations, and other fraudulent activities violating Sections 13(1)(c) and 13(1)(d). The trust's participation in PMGKY does not absolve it from wrongdoing. The CIT(A) failed to provide reasons justifying the trust's adherence to its objects. The accounts were unreliable due to the trustees' consistent involvement in fraud. The admission of undisclosed income under PMGKY and misuse of trust funds for taxes indicate deviation from charitable objectives. The AO's extrapolation was based on direct evidence of systematic fraud. The exemptions u/ss 11 and 12 were rightly denied, and income should be taxed at the maximum marginal rate u/s 164(2), excluding exemptions but giving credit for PMGKY disclosure after avoiding double additions.
The AO denied exemption u/s 11 to the assessee trust based on incriminating evidence of undisclosed income declared under PMGKY, systematic recovery of staff salaries, bogus corpus donations, and other fraudulent activities violating Sections 13(1)(c) and 13(1)(d). The trust's participation in PMGKY does not absolve it from wrongdoing. The CIT(A) failed to provide reasons justifying the trust's adherence to its objects. The accounts were unreliable due to the trustees' consistent involvement in fraud. The admission of undisclosed income under PMGKY and misuse of trust funds for taxes indicate deviation from charitable objectives. The AO's extrapolation was based on direct evidence of systematic fraud. The exemptions u/ss 11 and 12 were rightly denied, and income should be taxed at the maximum marginal rate u/s 164(2), excluding exemptions but giving credit for PMGKY disclosure after avoiding double additions.
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