Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
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ITAT addressed exemption under Section 11 for a public charitable trust. The tribunal examined whether sale of devotional articles constitutes a business activity disqualifying tax exemption. Despite revenue's argument that surplus income from sales negates exemption, ITAT found the trust's primary activities remained charitable, including feeding poor, providing education, and medical relief. The tribunal noted majority of income derived from donations and interest. Referencing SC precedent, ITAT determined sales at nominal cost do not automatically transform charitable activities into business. Administrative expenses and overall charitable objectives were considered. CIT(A)'s original exemption was upheld, and revenue's appeal was dismissed.
ITAT addressed exemption under Section 11 for a public charitable trust. The tribunal examined whether sale of devotional articles constitutes a business activity disqualifying tax exemption. Despite revenue's argument that surplus income from sales negates exemption, ITAT found the trust's primary activities remained charitable, including feeding poor, providing education, and medical relief. The tribunal noted majority of income derived from donations and interest. Referencing SC precedent, ITAT determined sales at nominal cost do not automatically transform charitable activities into business. Administrative expenses and overall charitable objectives were considered. CIT(A)'s original exemption was upheld, and revenue's appeal was dismissed.
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