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    <title>2025 (2) TMI 1427 - ITAT RAIPUR</title>
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    <description>Assessee&#039;s claim for exemption under the charitable-approval provision was allowable because the approval remained unwithdrawn and pre conditions were satisfied, so the exemption claim must be recognised. The denial of section 11 exemption was rejected to the extent that alleged excessive payments to related persons were not established; consequently the assessing officer&#039;s full disallowance under that head was vacated. Specific disallowances for student data processing, books, printing, VC house, advertisement and software expenses failed for lack of evidence of diversion to specified persons, so those additions cannot stand. Development charges treated as capital receipts were disallowed, but if treated as revenue and applied over 85% the exemption condition was satisfied. Assessment date and dispatch did not make the order time barred. Depreciation claim allowed following higher court precedents.</description>
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    <pubDate>Fri, 28 Feb 2025 00:00:00 +0530</pubDate>
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      <title>2025 (2) TMI 1427 - ITAT RAIPUR</title>
      <link>https://www.taxtmi.com/caselaws?id=466471</link>
      <description>Assessee&#039;s claim for exemption under the charitable-approval provision was allowable because the approval remained unwithdrawn and pre conditions were satisfied, so the exemption claim must be recognised. The denial of section 11 exemption was rejected to the extent that alleged excessive payments to related persons were not established; consequently the assessing officer&#039;s full disallowance under that head was vacated. Specific disallowances for student data processing, books, printing, VC house, advertisement and software expenses failed for lack of evidence of diversion to specified persons, so those additions cannot stand. Development charges treated as capital receipts were disallowed, but if treated as revenue and applied over 85% the exemption condition was satisfied. Assessment date and dispatch did not make the order time barred. Depreciation claim allowed following higher court precedents.</description>
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      <pubDate>Fri, 28 Feb 2025 00:00:00 +0530</pubDate>
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