Time limits for search-based assessments are a self-contained code; extension applies only with a transfer pricing reference, otherwise late orders ar...
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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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