Held\u00a0 that the assessee was not clear whether it received corpus donation. First, the assessee must clarify whether or not it received any such corpus donation, and if so, whether it was exempted under which provisions of law, particularly in the absence of registration under section\u00a012AA, which after amendment in section\u00a012A\u00a0by the Finance Act, 2007, with effect from June 1, 2007 was a condition precedent for exemption. That though the assessee had proved the identity of the lenders and their capacity by filing the record of agriculturists\u2019 showing sufficient land holding in their names the entire transaction of unsecured loan was received in cash and the assessee had shown alleged unsecured loan on daily basis. Unsecured loans\u00a0 on more than 50 occasions were shown only to avoid the rigours of section\u00a0269SS, and the genuineness of transactions was doubtful. Thus, all three conditions of section\u00a068\u00a0were not substantiated simultaneously by the assessee. The order of the Commissioner (Appeals) was proper.That the Commissioner (Appeals), after considering each and every item of expense had granted sufficient relief and reasonably restricted the disallowance to those expenses which were not verifiable. There was no justification for further reducing the disallowance.(AY.2013-14)<\/p>\n","protected":false},"excerpt":{"rendered":"
S. 11 : Property held for charitable purpose-Registration-Corpus Donations-Registration condition precedent for exemption in respect of corpus donations-Cash credits-Genuineness of loan is doubtful-Addition is proper-Business expenditure-Each item of expense considered and disallowance restricted to expenses not verifiable-No Justification for further reducing disallowance. [S.12AA, 68] <\/p>\n","protected":false},"author":3,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"jetpack_post_was_ever_published":false,"_jetpack_newsletter_access":"","_jetpack_dont_email_post_to_subs":false,"_jetpack_newsletter_tier_id":0,"_jetpack_memberships_contains_paywalled_content":false,"_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[21],"tags":[],"class_list":["post-43574","post","type-post","status-publish","format-standard","hentry","category-income-tax-act"],"acf":[],"jetpack_featured_media_url":"","jetpack_shortlink":"https:\/\/wp.me\/p9S2Rw-bkO","jetpack-related-posts":[],"jetpack_sharing_enabled":true,"_links":{"self":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/43574","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/users\/3"}],"replies":[{"embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/comments?post=43574"}],"version-history":[{"count":1,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/43574\/revisions"}],"predecessor-version":[{"id":43575,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/43574\/revisions\/43575"}],"wp:attachment":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/media?parent=43574"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/categories?post=43574"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/tags?post=43574"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}