Dependent Agent PE unresolved for lack of factual inquiry; arm's-length distribution accepted; royalty claim rejected; 15% refund interest (Section 24...
Exemption under s.10(23C)(iiiad) upheld; appeal allowed, interest and dividends excluded from annual receipts, disallowance deleted, capital gains exe...
ITAT upholds the Ld. CIT(A)'s directions, allowing the assessee's claim for exemption under section 11 and rejecting the AO's procedural denial where the claim was not timely in the return; the Tribunal finds the AO's action contrary to its own prior decision and beyond jurisdiction. The trust's 12A registration and belated filing of audit/Form 10 were condoned in light of administrative practice, entitling the trust to section 11 benefits. The Tribunal affirms the assessee's status as a local authority. Capital outlays, gratuity and superannuation contributions are treated as application of income; change in accounting method and accrued interest claims are accepted; wharfage income timing and environment monitoring income taxed in relevant year; leave encashment premium allowed; loss on asset sale remitted for recomputation; certain prior period expenses restored for verification.
ITAT upholds the Ld. CIT(A)'s directions, allowing the assessee's claim for exemption under section 11 and rejecting the AO's procedural denial where the claim was not timely in the return; the Tribunal finds the AO's action contrary to its own prior decision and beyond jurisdiction. The trust's 12A registration and belated filing of audit/Form 10 were condoned in light of administrative practice, entitling the trust to section 11 benefits. The Tribunal affirms the assessee's status as a local authority. Capital outlays, gratuity and superannuation contributions are treated as application of income; change in accounting method and accrued interest claims are accepted; wharfage income timing and environment monitoring income taxed in relevant year; leave encashment premium allowed; loss on asset sale remitted for recomputation; certain prior period expenses restored for verification.
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