Reasonable Cause for Late Return: penalty under section 271(1)(c) unsustainable where disclosure, audit filing and voluntary offer showed no concealme...
Proceeds of crime and property equivalent in value: failure to explain lawful source sustains attachment; lack of required notice can vitiate confirma...
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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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