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...
PCIT (Central), Gurgaon lacked subject-matter jurisdiction to decide renewal of charitable registration under section 12A(1)(ac)(ii) because the competent authority was the Commissioner of Income Tax (Exemptions), Chandigarh under the relevant CBDT notification. The Tribunal also held that renewal proceedings are confined to the genuineness of the activities and compliance with other laws relevant to the objects, and cannot be converted into cancellation proceedings. As the assessees were engaged in education, and the record did not discredit the genuineness of those charitable activities, past or minor irregularities could not justify refusal of renewal. The rejection orders were set aside and renewal directed.
PCIT (Central), Gurgaon lacked subject-matter jurisdiction to decide renewal of charitable registration under section 12A(1)(ac)(ii) because the competent authority was the Commissioner of Income Tax (Exemptions), Chandigarh under the relevant CBDT notification. The Tribunal also held that renewal proceedings are confined to the genuineness of the activities and compliance with other laws relevant to the objects, and cannot be converted into cancellation proceedings. As the assessees were engaged in education, and the record did not discredit the genuineness of those charitable activities, past or minor irregularities could not justify refusal of renewal. The rejection orders were set aside and renewal directed.
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