Political contribution deductions require assessee-specific proof before cash-back allegations can justify disallowance or unexplained-money additions...
ITAT allowed appeal concerning approval under s.10(23C)(vi) for educational institution converted from society to Section 8 Company. CIT(E) rejected approval citing new objects including medical facilities in memorandum. ITAT held medical centers and clinics are integral to medical education, providing practical training. No evidence showed assessee conducted activities beyond education. Original educational operations continued as going concern post-conversion. Matter remanded to CIT(E) to verify revised objects and grant approval after confirming removal of contested clauses. Conversion from society to company did not alter educational nature of institution's activities.
ITAT allowed appeal concerning approval under s.10(23C)(vi) for educational institution converted from society to Section 8 Company. CIT(E) rejected approval citing new objects including medical facilities in memorandum. ITAT held medical centers and clinics are integral to medical education, providing practical training. No evidence showed assessee conducted activities beyond education. Original educational operations continued as going concern post-conversion. Matter remanded to CIT(E) to verify revised objects and grant approval after confirming removal of contested clauses. Conversion from society to company did not alter educational nature of institution's activities.
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