Tribunal rules Section 13 does not apply without proof of benefit
The ITAT held that invoking Section 13 of the Income Tax Act is invalid when authorities fail to establish a direct connection between the assessee and specified persons. Without concrete evidence of undue benefit, tax additions under this provision cannot be sustained.
Effective Not specified in the update
For professionals: Meticulously audit all financial flows involving specified individuals to safeguard trust exemption statuses. · Maintain airtight documentation proving that transactions occur at arm's length and benefit core institutional objectives. · Ensure concrete proof of benefit or lack thereof is established, as tax authorities cannot rely on assumptions or mere suspicions under Section 13.
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