“Section 13(2)(e)”

Income of a trust that is taxable at the maximum marginal rate should be taxed accordingly, while other income is eligible for exemption under Section 11 of the Income-tax Act.

When computing the income of a charitable trust for exemption under Section 11, depreciation must be allowed as an application of income based on commercial principles. This does not constitute a double deduction.

The Commissioner is justified in rejecting an application for registration or recognition (e.g., under sections 12A, 12AA, or 80G) if there is no material to establish the genuineness of the trust's activities or if no charitable work has been undertaken during the relevant period.

The cost base for applying the operating profit over total cost margin in transfer pricing cannot be broadened to include costs not incurred by the assessee. Tax authorities cannot impute costs incurred by third parties or associated enterprises for computing the assessee's net profit margin.

A charitable trust can claim depreciation on a capital asset even if its cost was treated as application of income for charitable purposes. Allowing depreciation does not constitute double allowance.

Authorities cannot reject an application for registration under section 12A or recognition under section 80G solely on the ground of absence of activities when the trust has approached for registration within a reasonable time after its formation. The objects of the trust must be examined.

When an assessee is engaged in charitable activity for the advancement of objects of general public utility, the proviso to Section 2(15) of the Income Tax Act, 1961, will not be applicable.

Interest on outstanding receivables arising during business is considered an international transaction under the definition of 'capital financing'.