Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
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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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