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External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
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Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
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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