https://www.taxtmi.com/caselaws?id=436362 A government-controlled corporation was treated as a separate taxable entity, so Article 289 immunity was unavailable because the income was not the income of the State itself. The tax character of project-related reimbursements depended on their true purpose: amounts meeting capital cost could be capital receipts, while reimbursements of recurring expenditure would remain revenue in nature, requiring factual verification. Gifts, donations, and related relief were governed by section 37 and section 80G: only expenditure laid out wholly and exclusively for business could qualify, while charitable donation relief needed supporting verification. Forward contract premium, exchange loss, and interest on temporary deposits also turned on the source, purpose, and business stage, requiring issue-specific examination. en-us Thu, 06 Apr 2023 00:00:00 +0530 Mon, 10 Apr 2023 13:21:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=436362 A government-controlled corporation was treated as a separate taxable entity, so Article 289 immunity was unavailable because the income was not the income of the State itself. The tax character of project-related reimbursements depended on their true purpose: amounts meeting capital cost could be capital receipts, while reimbursements of recurring expenditure would remain revenue in nature, requiring factual verification. Gifts, donations, and related relief were governed by section 37 and section 80G: only expenditure laid out wholly and exclusively for business could qualify, while charitable donation relief needed supporting verification. Forward contract premium, exchange loss, and interest on temporary deposits also turned on the source, purpose, and business stage, requiring issue-specific examination. Case-Laws Income Tax Thu, 06 Apr 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=436362