Consultancy fees claimed as business expense-can tax disallowance rest on survey suspicion despite invoices, contracts and bank trail? Appeal dismisse...
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The note addresses legal limits on cancelling a tax-exempt entity's registration under the post 2022 statutory scheme, holding that cancellation must target defects in the organisation's predominant activities rather than isolated financial transactions; breaches that divert benefit to specified persons give rise to assessment-stage consequences, not automatic cancellation; show cause notices must identify the exact statutory limb relied upon or proceedings are jurisdictionally vitiated; the cancellation regime is prospective and cannot be applied to pre enactment periods; and an assessing officer's transfer under assessment provisions does not confer independent registration cancellation power absent specific delegation.
The note addresses legal limits on cancelling a tax-exempt entity's registration under the post 2022 statutory scheme, holding that cancellation must target defects in the organisation's predominant activities rather than isolated financial transactions; breaches that divert benefit to specified persons give rise to assessment-stage consequences, not automatic cancellation; show cause notices must identify the exact statutory limb relied upon or proceedings are jurisdictionally vitiated; the cancellation regime is prospective and cannot be applied to pre enactment periods; and an assessing officer's transfer under assessment provisions does not confer independent registration cancellation power absent specific delegation.
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