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Randox Laboratories (India) Private ... vs Dcit, Bangalore on 17 July, 2019

Before us, it only a professional association of persons who have formed the trusts duly approved by Maharashtra Medical Council and duly registered u/s.12A/12AA/12AB and working for the charitable objects and advancement of education and therefore ld.PCIT erred in applying the ratio laid down by the Hon‟ble Apex Court in the 72 ITA No.518, 522, 549 and 417/PUN/2023 Poona Obstetrics and Gynaecological Society and 3 others case of M/s. Apex Laboratories Pvt. Ltd. vs. DCIT (supra) on the facts of the instant case alleging the assessee(s) trust of committing the ‗specified violation'. In view the above, we are of the considered view that on merits of the case, assessee(s) trusts deserve to succeed and accordingly finding of ld.PCIT cancelling the registration of the assessee(s) trusts for the alleged violation provided in section 12AB(4) of the Act is hereby reversed and the registration granted u/s.12A/12AA/12AB of the Act are reinstated and will remain in force. Grounds of appeal No.1, 2, 3 and 4 are allowed.
Income Tax Appellate Tribunal - Bangalore Cites 17 - Cited by 13 - Full Document

M/S Apex Laboratories P. Ltd. vs The Deputy Commissioner Of Income Tax ... on 22 February, 2022

ITA No.518, 522, 549 and 417/PUN/2023 Poona Obstetrics and Gynaecological Society and 3 others 2.11 Reliance in this regard is placed on the decision of Hon'ble Supreme Court in the case of Apex Laboratories (P) Ltd vs Deputy Commissioner of Income Tax where it was held that, ―36. In the present case too, the incentives (or "freebies") given by Apex, to the doctors, had a direct result of exposing the recipients to the odium of sanctions, leading to a ban on their practice of medicine. Those sanctions are mandated by law, as they are embodied in the code of conduct and ethics, which are normative, and have legally binding effect. The conceded participation of the assessee- i.e., the provider or donor- was plainly prohibited, as far as their receipt by the medical practitioners was concerned. That medical practitioners were forbidden from accepting such gifts, or "freebies" was no less a prohibition on the part of their giver, or donor, i.e., Apex‖ It is also a known principle that what cannot be done directly, cannot be achieved indirectly.
Supreme Court of India Cites 41 - Cited by 189 - S R Bhat - Full Document
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