Independent manufacturing undertaking eligibility preserves Section 80IA/80IB deductions, while machinery kept ready for use qualifies for depreciatio...
Assessing Officer Satisfaction Requirement Bars Penalty for Cash Receipt in Immovable-Property Sale Cases Where Initiation Lacks Recorded Satisfaction...
Self-assessed import entries remain appealable, while bona fide classification disputes without misdeclaration cannot justify confiscation or penaltie...
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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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