Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
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ITAT reversed CIT(A)'s decision and upheld AO's denial of exemption under section 10(23C)(vi). While providing education and integrated hostel facilities qualifies as charitable activity, operating hostels separately on commercial basis constitutes business activity. Following Supreme Court's precedent in Ahmedabad Urban Development Authority case, ITAT held that charging substantially higher fees over cost amounts to "trade, commerce or business." The Trust's hostel operations generating surplus of Rs. 6.21 crores exceeded mere cost recovery with nominal markup. Since commercial activities were not incidental to educational purposes and exceeded 20% threshold under section 2(15), the Trust failed to meet "solely educational purposes" requirement. Revenue's appeal allowed.
ITAT reversed CIT(A)'s decision and upheld AO's denial of exemption under section 10(23C)(vi). While providing education and integrated hostel facilities qualifies as charitable activity, operating hostels separately on commercial basis constitutes business activity. Following Supreme Court's precedent in Ahmedabad Urban Development Authority case, ITAT held that charging substantially higher fees over cost amounts to "trade, commerce or business." The Trust's hostel operations generating surplus of Rs. 6.21 crores exceeded mere cost recovery with nominal markup. Since commercial activities were not incidental to educational purposes and exceeded 20% threshold under section 2(15), the Trust failed to meet "solely educational purposes" requirement. Revenue's appeal allowed.
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