Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
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...
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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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