Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Eligibility for exemption depends on strict construction of the product description; reapers without binder are ineligible, but confiscation and penal...
Denial of exemption under sections 11 and 12 was sustained where the trust's receipts arose from government work contracts and not from donations or charitable activity; TDS under contract payments supported this commercial character. The article applies the charitable-purpose versus commercial-contract test and the incidental-business doctrine, finding contract income primary, not incidental, and absence of separate books fatal to exemption under the charitable activity definition. Use of trust funds for trustee benefit or payments on running account to specified persons attracts the prohibition on directing income to specified persons and loss of exemption with taxation at the maximum marginal rate.
Denial of exemption under sections 11 and 12 was sustained where the trust's receipts arose from government work contracts and not from donations or charitable activity; TDS under contract payments supported this commercial character. The article applies the charitable-purpose versus commercial-contract test and the incidental-business doctrine, finding contract income primary, not incidental, and absence of separate books fatal to exemption under the charitable activity definition. Use of trust funds for trustee benefit or payments on running account to specified persons attracts the prohibition on directing income to specified persons and loss of exemption with taxation at the maximum marginal rate.
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