Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
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ITAT allowed the appeal and set aside the rejection of exemption under s.10(23C)(vi) in favour of the assessee Society. The Tribunal held that generation of recurring surplus per se does not establish disqualification or profit motive where the Society's objects are educational and surpluses are applied for educational purposes; transfer to a School Development Fund and acquisition of land in the Society's name are not conclusive indicia of non-application. The matter is remitted to the CIT(A) to examine whether the funds and assets have been applied exclusively for the Society's objects and to determine eligibility for registration under s.10(23C)(vi) accordingly.
ITAT allowed the appeal and set aside the rejection of exemption under s.10(23C)(vi) in favour of the assessee Society. The Tribunal held that generation of recurring surplus per se does not establish disqualification or profit motive where the Society's objects are educational and surpluses are applied for educational purposes; transfer to a School Development Fund and acquisition of land in the Society's name are not conclusive indicia of non-application. The matter is remitted to the CIT(A) to examine whether the funds and assets have been applied exclusively for the Society's objects and to determine eligibility for registration under s.10(23C)(vi) accordingly.
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