Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
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ITAT held that exemption under section 10(46) depends on the nature of the receipt and not on the year in which it is recognised in the accounts. Prior period regulatory receipts such as licence fees, advances and other regulatory income remained exempt because they were intrinsically linked to the statutory functions of the Commission, and the corresponding addition was deleted. The Tribunal also held that incidental non-commercial receipts, including interest on House Building Advance, personal use of office vehicle, miscellaneous income and related interest receipts, were ancillary to the exempt regulatory activity and retained their exempt character. The additions on both counts were therefore unsustainable and were directed to be deleted.
ITAT held that exemption under section 10(46) depends on the nature of the receipt and not on the year in which it is recognised in the accounts. Prior period regulatory receipts such as licence fees, advances and other regulatory income remained exempt because they were intrinsically linked to the statutory functions of the Commission, and the corresponding addition was deleted. The Tribunal also held that incidental non-commercial receipts, including interest on House Building Advance, personal use of office vehicle, miscellaneous income and related interest receipts, were ancillary to the exempt regulatory activity and retained their exempt character. The additions on both counts were therefore unsustainable and were directed to be deleted.
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