Capital Gain Deductibility: proportionate IPO and PMS expenses held allowable against capital gains where netting and nexus to transfer are establishe...
Admissibility of Documentary Evidence: appellate authority may admit self explanatory documents on first production and uphold deletion of unexplained...
Renewal of charitable registration under section 12A(1)(ac)(ii) had to be decided by the Commissioner of Income-tax (Exemptions), and transfer of PAN or assessment jurisdiction did not confer subject-matter jurisdiction on the Principal Commissioner (Central); the impugned rejection was therefore without jurisdiction. On merits, the renewal enquiry was confined to genuineness of activities and compliance with allied laws, and could not be expanded into cancellation-style allegations under section 12AB(4). Search-period material, minor irregularities, and Settlement Commission observations did not justify denial where education activity was otherwise accepted. The Tribunal directed renewal of registration and issue of the certificate.
Renewal of charitable registration under section 12A(1)(ac)(ii) had to be decided by the Commissioner of Income-tax (Exemptions), and transfer of PAN or assessment jurisdiction did not confer subject-matter jurisdiction on the Principal Commissioner (Central); the impugned rejection was therefore without jurisdiction. On merits, the renewal enquiry was confined to genuineness of activities and compliance with allied laws, and could not be expanded into cancellation-style allegations under section 12AB(4). Search-period material, minor irregularities, and Settlement Commission observations did not justify denial where education activity was otherwise accepted. The Tribunal directed renewal of registration and issue of the certificate.
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