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Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
The ITAT allowed the appeal of the Appellant-Trust, set aside the PCIT-Central's order canceling registration under s.12AB(4)(ii) and restored registration granted under s.12A. The Tribunal held the cancellation rested on suspicion and surmise without evidentiary foundation: ledger records established receipt of amounts from book sales either in the same or subsequent year, negating any inference of diverted consideration or misapplication of trust property. The Trust's activities, including sale/distribution of donated books, fall within its stated objects (including Clause-z) and income has been applied for charitable objects; there was no proof of non-compliance with registration conditions or proscribed benefit under s.13(3). Appeal allowed.
The ITAT allowed the appeal of the Appellant-Trust, set aside the PCIT-Central's order canceling registration under s.12AB(4)(ii) and restored registration granted under s.12A. The Tribunal held the cancellation rested on suspicion and surmise without evidentiary foundation: ledger records established receipt of amounts from book sales either in the same or subsequent year, negating any inference of diverted consideration or misapplication of trust property. The Trust's activities, including sale/distribution of donated books, fall within its stated objects (including Clause-z) and income has been applied for charitable objects; there was no proof of non-compliance with registration conditions or proscribed benefit under s.13(3). Appeal allowed.
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