Benami transaction and beneficial ownership: documentary and circumstantial evidence show payors were true beneficiaries, resulting in PBPTA consequen...
Denial of Preferential Treatment under SAFTA overturned where unchallenged Country of Origin certificate warranted exemption under Notification benefi...
Continuing offence of money-laundering: discharge set aside and proceedings reinstated where laundering continued after inclusion of predicate offence...
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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