Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Threshold exemption excludes exempt services, while stamp-paper purchases avoid reverse charge; consequential service tax penalties were also set asid...
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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