The Tribunal held that land cost must be allocated based on saleable/built-up area under the JDA, not total land area. It directed adoption of a higher per-sq-ft land cost while recomputing capital gains.
The Tribunal held that estimating business income at 10% of turnover without citing comparable cases or industry benchmarks is unsustainable. Arbitrary profit estimation must be supported by material evidence.
The Tribunal upheld cancellation after finding that funding practices influenced editorial content and political narratives. The ruling confirms that such conduct constitutes specified violations warranting loss of charitable status.
ITAT Bangalore held that disallowance of entire business losses by Assessing Officer without pointing out specific defects is not permissible. Accordingly, appeal of assessee allowed and order set aside.
The Assessing Officer assumed that no return of income was filed while recording reasons under section 147. The Tribunal ruled that such factually incorrect reasons vitiate the assumption of jurisdiction itself.
The Tribunal held that interest income earned by a co-operative society from deposits with co-operative banks is eligible for deduction under Section 80P(2)(d), subject to verification of amounts.
The Revenue argued AMP functions required separate compensation under DEMPE principles. The Tribunal rejected this, holding that consistent past rulings prevail absent material factual change.
The Tribunal held that running coaching classes for substantial fees does not qualify as charitable education. In the absence of evidence of free or subsidized services, exemption under section 11 was rightly denied.
The Tribunal held that solar power generation under a CSR structure is not charitable when the dominant benefit accrues to a single corporate entity. The environmental activity must primarily benefit the public to qualify for Section 12AB registration.
The Tribunal ruled that inclusion of giant companies distorted arm’s length results for a small captive service provider. High-turnover companies were excluded to ensure meaningful comparability.
