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...
The ITAT upheld that the assessee is a charitable institution established under enabling metropolitan statutes and falls within "general public utility" under s.2(15), its registration u/s.12AA remaining valid. The Tribunal held the proviso to s.2(15) inapplicable and directed that exemption u/s.11 (and consequentially u/s.12) be allowed; Revenue's grounds challenging this (grounds nos.2, 3 and 5) were dismissed and the CIT(A)'s order sustained. Treatment of lease premium and TDRs as non-taxable for the relevant years, and the disallowance/ notional interest additions relating to public deposits/advances, were rendered academic in view of the exemption holding and prior Coordinate Bench rulings.
The ITAT upheld that the assessee is a charitable institution established under enabling metropolitan statutes and falls within "general public utility" under s.2(15), its registration u/s.12AA remaining valid. The Tribunal held the proviso to s.2(15) inapplicable and directed that exemption u/s.11 (and consequentially u/s.12) be allowed; Revenue's grounds challenging this (grounds nos.2, 3 and 5) were dismissed and the CIT(A)'s order sustained. Treatment of lease premium and TDRs as non-taxable for the relevant years, and the disallowance/ notional interest additions relating to public deposits/advances, were rendered academic in view of the exemption holding and prior Coordinate Bench rulings.
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