Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
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Corpus donations, being distinct from incomes derived from trust property, are granted exemption separately u/s 11(1)(a) and 11(1)(d) of the Act. There is no overlapping exemption. Different incomes recognized for exemption have been separately granted exemption. Corpus donations cannot claim exemption under both sub-clauses (d) and (a) of Section 11(1). The assessee was unable to point out any infirmity in this interpretation during the hearing before the Appellate Tribunal. The decisions relied upon by the assessee were either distinguishable on facts or rendered without considering the clear provision of law. The assessee's appeal seeking exemption u/s 11(1)(a) for corpus donations received was dismissed.
Corpus donations, being distinct from incomes derived from trust property, are granted exemption separately u/s 11(1)(a) and 11(1)(d) of the Act. There is no overlapping exemption. Different incomes recognized for exemption have been separately granted exemption. Corpus donations cannot claim exemption under both sub-clauses (d) and (a) of Section 11(1). The assessee was unable to point out any infirmity in this interpretation during the hearing before the Appellate Tribunal. The decisions relied upon by the assessee were either distinguishable on facts or rendered without considering the clear provision of law. The assessee's appeal seeking exemption u/s 11(1)(a) for corpus donations received was dismissed.
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