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SC affirmed the High Court's reversal of the ITAT and upheld the AO/Appellate Commissioner's disallowance of exemption under s.11, holding the trust's receipt of an interest-free secured loan to its manager did not meet charitable activity under s.2(15). The Court accepted that the asserted 10% interest was not evidenced in accounting records or audit reports and that a post hoc resolution was unreliable; s.13(1)(c) rendered the institution's entire income taxable if any part benefits specified persons. The appeal was dismissed on merits; however, the appellant-assessee was granted liberty to make a representation to the AO regarding the appropriate quantum of tax payable.
SC affirmed the High Court's reversal of the ITAT and upheld the AO/Appellate Commissioner's disallowance of exemption under s.11, holding the trust's receipt of an interest-free secured loan to its manager did not meet charitable activity under s.2(15). The Court accepted that the asserted 10% interest was not evidenced in accounting records or audit reports and that a post hoc resolution was unreliable; s.13(1)(c) rendered the institution's entire income taxable if any part benefits specified persons. The appeal was dismissed on merits; however, the appellant-assessee was granted liberty to make a representation to the AO regarding the appropriate quantum of tax payable.
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