Electronic WhatsApp evidence without authentication or independent corroboration cannot sustain an unexplained-investment addition based on third-part...
Mutual current-account transactions excluded from deemed dividend treatment where no fresh borrowing arose; unsupported unsecured-loan addition also f...
ITAT allowed the appeal of a charitable entity challenging denial of exemption under section 11. The assessee accumulated funds during FY 2016-17 and utilized them in the sixth year (FY 2022-23). CPC treated the unutilized amount as deemed income in AY 2023-24. ITAT held that since utilization occurred before 31.03.2023, within the year immediately following the prescribed five-year period, and amendments to section 11(3) were prospective, taxation was improper. The tribunal ruled that if taxation was warranted, it should have occurred in AY 2022-23 when the five-year period expired on 31.03.2022, not in AY 2023-24. ITAT set aside the lower authority's order and directed deletion of the adjustment, allowing the assessee's grounds.
ITAT allowed the appeal of a charitable entity challenging denial of exemption under section 11. The assessee accumulated funds during FY 2016-17 and utilized them in the sixth year (FY 2022-23). CPC treated the unutilized amount as deemed income in AY 2023-24. ITAT held that since utilization occurred before 31.03.2023, within the year immediately following the prescribed five-year period, and amendments to section 11(3) were prospective, taxation was improper. The tribunal ruled that if taxation was warranted, it should have occurred in AY 2022-23 when the five-year period expired on 31.03.2022, not in AY 2023-24. ITAT set aside the lower authority's order and directed deletion of the adjustment, allowing the assessee's grounds.
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