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    <title>2025 (10) TMI 1349 - ITAT CHANDIGARH</title>
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    <description>Denial of exemption and cancellation of registration arose from operation of fuel stations generating substantial receipts. The tribunal accepted that the petrol pumps were transferred by government constraints and operated without profit motive, applying the ancillary or incidental activity doctrine and concluding surplus was applied to charitable objects, with cancellation on that ground unsustainable. Allegations of diversion of income and lack of separate books were unsupported by evidence and rejected, with genuineness of activities affirmed. The tribunal further applied the principle that cancellation cannot be made retrospectively beyond the year of violation and subsequent years, rendering earlier retrospective cancellation impermissible; appeal allowed.</description>
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      <title>2025 (10) TMI 1349 - ITAT CHANDIGARH</title>
      <link>https://www.taxtmi.com/caselaws?id=465990</link>
      <description>Denial of exemption and cancellation of registration arose from operation of fuel stations generating substantial receipts. The tribunal accepted that the petrol pumps were transferred by government constraints and operated without profit motive, applying the ancillary or incidental activity doctrine and concluding surplus was applied to charitable objects, with cancellation on that ground unsustainable. Allegations of diversion of income and lack of separate books were unsupported by evidence and rejected, with genuineness of activities affirmed. The tribunal further applied the principle that cancellation cannot be made retrospectively beyond the year of violation and subsequent years, rendering earlier retrospective cancellation impermissible; appeal allowed.</description>
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