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Income Tax - Highlights / Catch Notes

Home Highlights April 2025 Year 2025 This

ITAT ruled on a trust's tax exemption under section 11, ...


Trust Tax Exemption Upheld: Section 11 Protects Income, Limits Penalty Scope to Specific Violations, Preserves Depreciation Claims

April 17, 2025

Case Laws     Income Tax     AT

ITAT ruled on a trust's tax exemption under section 11, addressing multiple key issues: The tribunal held that exemption denial under section 13 should be limited only to the specific income violating provisions, not the entire trust income. The maximum marginal rate shall apply exclusively to the contravened income portion (Rs. 1,80,000), not the complete trust income. Regarding section 69A, impounded unverified documents were deemed insufficient for making unexplained income additions. The tribunal allowed exemption under section 11, permitted depreciation claim as an application of income, and confirmed that the trust could claim either depreciation or capital expenditure application, ensuring statutory compliance while preventing potential administrative overreach.

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