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...
ITAT allowed the appeal of a charitable trust registered under section 12A, reversing the AO's denial of section 11 exemption. The AO had applied mutuality principles and the first proviso to section 2(15), treating the assessee as predominantly a mutual association and taxing interest income. ITAT held that the assessee conducted activities for general public utility, including free annual events benefiting insurance consumers and brokers, not exclusively for members. The tribunal found no evidence of trade, commerce, or business activities for fees as required under the proviso to section 2(15). ITAT concluded that mutuality principles were inapplicable since the trust served both members and the general public through charitable activities. The addition towards interest and other income was directed to be deleted, granting full exemption under section 11.
ITAT allowed the appeal of a charitable trust registered under section 12A, reversing the AO's denial of section 11 exemption. The AO had applied mutuality principles and the first proviso to section 2(15), treating the assessee as predominantly a mutual association and taxing interest income. ITAT held that the assessee conducted activities for general public utility, including free annual events benefiting insurance consumers and brokers, not exclusively for members. The tribunal found no evidence of trade, commerce, or business activities for fees as required under the proviso to section 2(15). ITAT concluded that mutuality principles were inapplicable since the trust served both members and the general public through charitable activities. The addition towards interest and other income was directed to be deleted, granting full exemption under section 11.
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