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...
ITAT held that the rejection of registration u/s 12A(1)(ac)(iii) and cancellation of provisional registration u/s 12AB of the trust was unsustainable. Applying the governing precedent, the Tribunal found that mere origin from a community platform and beneficiary description as a "Samaj" does not ipso facto render the trust for a particular religious community or caste; a fact-specific inquiry is required into whether the community constitutes a religious denomination and whether activities are exclusionary in practice. The CIT(Exemption) failed to distinguish "caste" from "religious community" and made no categorical findings, notwithstanding financials evidencing public-welfare expenditure. The impugned order was quashed and the matter remitted for fresh, reasoned adjudication.
ITAT held that the rejection of registration u/s 12A(1)(ac)(iii) and cancellation of provisional registration u/s 12AB of the trust was unsustainable. Applying the governing precedent, the Tribunal found that mere origin from a community platform and beneficiary description as a "Samaj" does not ipso facto render the trust for a particular religious community or caste; a fact-specific inquiry is required into whether the community constitutes a religious denomination and whether activities are exclusionary in practice. The CIT(Exemption) failed to distinguish "caste" from "religious community" and made no categorical findings, notwithstanding financials evidencing public-welfare expenditure. The impugned order was quashed and the matter remitted for fresh, reasoned adjudication.
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TaxTMI 
TaxTMI 
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