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 ...
ITAT ruled on income computation under Section 11(1) for a charitable trust manufacturing artificial limbs. Revenue generated from manufacturing activities qualifies as eligible income for accumulation purposes, considering the trust's primary objective of serving disabled persons with affordable prosthetics. The Tribunal directed 15% accumulation under Section 11(1)(a) to be calculated on gross receipts. However, loans received under ADIP and ADIP-SSA schemes were excluded from income computation under Section 11(1), though they can be considered as application of income during utilization year. The trust exceeded the 85% income utilization requirement during the assessment year. Ground nos. 2 and 3 were allowed, while ground no. 4 was dismissed.
ITAT ruled on income computation under Section 11(1) for a charitable trust manufacturing artificial limbs. Revenue generated from manufacturing activities qualifies as eligible income for accumulation purposes, considering the trust's primary objective of serving disabled persons with affordable prosthetics. The Tribunal directed 15% accumulation under Section 11(1)(a) to be calculated on gross receipts. However, loans received under ADIP and ADIP-SSA schemes were excluded from income computation under Section 11(1), though they can be considered as application of income during utilization year. The trust exceeded the 85% income utilization requirement during the assessment year. Ground nos. 2 and 3 were allowed, while ground no. 4 was dismissed.
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