Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Whether the assessee's activities qualified as "charitable purpose" under s.2(15) and thus exemption under s.11: tribunal held that registration u/s 12A creates a presumption of charitable objects unless contrary to s.2(15) or ss.13(1)(c)/(d); passive interest from mandated investments u/s11(5) is not commercial activity and does not attract the proviso to s.2(15), relying on jurisdictional precedent, therefore interest income remains exempt under s.11 - outcome: exemption upheld and additions deleted. Whether corpus donations are taxable: corpus receipts are capital and exempt u/s11(1)(d); no material for s.13 breach - outcome: exemption maintained. - ITAT
Whether the assessee's activities qualified as "charitable purpose" under s.2(15) and thus exemption under s.11: tribunal held that registration u/s 12A creates a presumption of charitable objects unless contrary to s.2(15) or ss.13(1)(c)/(d); passive interest from mandated investments u/s11(5) is not commercial activity and does not attract the proviso to s.2(15), relying on jurisdictional precedent, therefore interest income remains exempt under s.11 - outcome: exemption upheld and additions deleted. Whether corpus donations are taxable: corpus receipts are capital and exempt u/s11(1)(d); no material for s.13 breach - outcome: exemption maintained. - ITAT
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