Co-operative society's mandatory reserve and share capital fixed deposits with banks-interest treated as business income under 80P(2)(a)(iii) deductio...
Income tax reassessment reopening after four years on investigation tip, without s.147 proviso disclosure failure, struck down as borrowed satisfactio...
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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