Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
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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