Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
Section 80P deduction for co-operative societies remains available despite nominal members and housing society status, with limited interest income tr...
Application of the rule excluding tax-exempt status where specified persons derive benefit must be read with the provision defining persons connected to the trust; here the signatories did not derive direct or indirect benefit from the sub-grant and the foreign university was not a connected person, so the provision invoking denial of exemption is not justified. On applicability of tax exemption for application of funds to charitable purposes, only assessment year 2010-11 showed under-application below the prescribed percentage, and the Assessing Officer is directed to restrict disallowance to the short application amount for that year.
Application of the rule excluding tax-exempt status where specified persons derive benefit must be read with the provision defining persons connected to the trust; here the signatories did not derive direct or indirect benefit from the sub-grant and the foreign university was not a connected person, so the provision invoking denial of exemption is not justified. On applicability of tax exemption for application of funds to charitable purposes, only assessment year 2010-11 showed under-application below the prescribed percentage, and the Assessing Officer is directed to restrict disallowance to the short application amount for that year.
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