https://www.taxtmi.com/caselaws?id=385783 Advertising contribution receipts were held taxable because the common fund was not confined to a true mutual set-up: contributors and beneficiaries were not identical, outside entities contributed, and the activity had a commercial character. The claim of diversion at source by overriding title also failed because the receipts were first credited as income and only later applied to advertising and promotion, making the expenditure an application of income rather than a prior diversion. The challenge to the AY 2001-02 surplus was barred by finality and merger after prior High Court adjudication, while deletion of the unverified sundry creditors addition for AY 2008-09 was upheld on the basis of creditor-wise particulars, PAN details, remand material, and subsequent payments. en-us Mon, 09 Sep 2019 00:00:00 +0530 Fri, 13 Sep 2019 06:00:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=385783 Advertising contribution receipts were held taxable because the common fund was not confined to a true mutual set-up: contributors and beneficiaries were not identical, outside entities contributed, and the activity had a commercial character. The claim of diversion at source by overriding title also failed because the receipts were first credited as income and only later applied to advertising and promotion, making the expenditure an application of income rather than a prior diversion. The challenge to the AY 2001-02 surplus was barred by finality and merger after prior High Court adjudication, while deletion of the unverified sundry creditors addition for AY 2008-09 was upheld on the basis of creditor-wise particulars, PAN details, remand material, and subsequent payments. Case-Laws Income Tax Mon, 09 Sep 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=385783