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 ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Threshold exemption excludes exempt services, while stamp-paper purchases avoid reverse charge; consequential service tax penalties were also set asid...
ITAT ruled on a trust's tax exemption under section 11, addressing multiple key issues: The tribunal held that exemption denial under section 13 should be limited only to the specific income violating provisions, not the entire trust income. The maximum marginal rate shall apply exclusively to the contravened income portion (Rs. 1,80,000), not the complete trust income. Regarding section 69A, impounded unverified documents were deemed insufficient for making unexplained income additions. The tribunal allowed exemption under section 11, permitted depreciation claim as an application of income, and confirmed that the trust could claim either depreciation or capital expenditure application, ensuring statutory compliance while preventing potential administrative overreach.
ITAT ruled on a trust's tax exemption under section 11, addressing multiple key issues: The tribunal held that exemption denial under section 13 should be limited only to the specific income violating provisions, not the entire trust income. The maximum marginal rate shall apply exclusively to the contravened income portion (Rs. 1,80,000), not the complete trust income. Regarding section 69A, impounded unverified documents were deemed insufficient for making unexplained income additions. The tribunal allowed exemption under section 11, permitted depreciation claim as an application of income, and confirmed that the trust could claim either depreciation or capital expenditure application, ensuring statutory compliance while preventing potential administrative overreach.
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