Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
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The ITAT upheld the exemption under section 11 for the assessee, a development authority, recognizing it as a charitable entity within the meaning of section 2(15), consistent with prior decisions and Supreme Court precedents. The proviso to section 2(15) was held inapplicable, as the assessee's object included providing shelter to the homeless. Additionally, amounts credited to the infrastructure development and reserve funds were held not taxable in the assessee's hands, since these funds belong to the State and the assessee acts merely as custodian. The tribunal concluded that utilization of these funds for general utility further supported exemption, thereby deciding all grounds in favor of the assessee.
The ITAT upheld the exemption under section 11 for the assessee, a development authority, recognizing it as a charitable entity within the meaning of section 2(15), consistent with prior decisions and Supreme Court precedents. The proviso to section 2(15) was held inapplicable, as the assessee's object included providing shelter to the homeless. Additionally, amounts credited to the infrastructure development and reserve funds were held not taxable in the assessee's hands, since these funds belong to the State and the assessee acts merely as custodian. The tribunal concluded that utilization of these funds for general utility further supported exemption, thereby deciding all grounds in favor of the assessee.
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