Consultancy fees claimed as business expense-can tax disallowance rest on survey suspicion despite invoices, contracts and bank trail? Appeal dismisse...
Registration under s.12AA was denied because the applicant's stated objects and actual activities were predominantly software development and start-up consultancy, which did not fall within any limb of "charitable purpose" under s.2(15). The authority further held that the applicant's dominant financing from a commercial entity, linked to strategic advisory arrangements, did not constitute income eligible for exemption under ss.11-12, as the receipts were in substance consideration for commercial services. In the absence of any material rebutting these findings, the denial of registration was upheld and the appeal was dismissed - ITAT
Registration under s.12AA was denied because the applicant's stated objects and actual activities were predominantly software development and start-up consultancy, which did not fall within any limb of "charitable purpose" under s.2(15). The authority further held that the applicant's dominant financing from a commercial entity, linked to strategic advisory arrangements, did not constitute income eligible for exemption under ss.11-12, as the receipts were in substance consideration for commercial services. In the absence of any material rebutting these findings, the denial of registration was upheld and the appeal was dismissed - ITAT
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