Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
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Exemption under section 11(2) could not be denied solely because Form No. 10 described the accumulation purpose as "purpose of the trust" when no substantive breach of sections 11 or 13(1)(d) was shown. The Tribunal noted that the assessee remained registered under section 12A and that no violation was established in the relevant year, earlier years, or during utilisation of the accumulated income. Applying the principle in Bochasanwasi Shri Akshar Purshottam Public Charitable Trust, it held that greater specificity in Form No. 10 was not required in the absence of any statutory non-compliance. The disallowance and consequential taxation were deleted.
Exemption under section 11(2) could not be denied solely because Form No. 10 described the accumulation purpose as "purpose of the trust" when no substantive breach of sections 11 or 13(1)(d) was shown. The Tribunal noted that the assessee remained registered under section 12A and that no violation was established in the relevant year, earlier years, or during utilisation of the accumulated income. Applying the principle in Bochasanwasi Shri Akshar Purshottam Public Charitable Trust, it held that greater specificity in Form No. 10 was not required in the absence of any statutory non-compliance. The disallowance and consequential taxation were deleted.
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