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...
Charitable status under section 2(15) turned on the manner of application of income read with the stated objects in the memorandum of association. The High Court found no rational basis to treat the deployment of ex-servicemen as security guards as a separate business activity, since the Commissioner had accepted the other income-generating activities as aligned with the main objects. Concurrent findings also showed a low net profit ratio and that the activity was directed to the upliftment of ex-servicemen and their families, with only limited retention for administrative expenses. The Tribunal's conclusion that the institution was charitable and entitled to registration was therefore left undisturbed, and the appeal was dismissed.
Charitable status under section 2(15) turned on the manner of application of income read with the stated objects in the memorandum of association. The High Court found no rational basis to treat the deployment of ex-servicemen as security guards as a separate business activity, since the Commissioner had accepted the other income-generating activities as aligned with the main objects. Concurrent findings also showed a low net profit ratio and that the activity was directed to the upliftment of ex-servicemen and their families, with only limited retention for administrative expenses. The Tribunal's conclusion that the institution was charitable and entitled to registration was therefore left undisturbed, and the appeal was dismissed.
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