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...
Approval under section 80G cannot be denied merely because a trust deed contains religious objects or some religious activity is shown, since section 80G(5B) permits religious expenditure up to five per cent of total income in the relevant previous year. Rejection based only on the religious nature of the objects and activities, without a finding that the statutory limit was exceeded, is unsustainable. The matter was set aside and remanded for a categorical finding on the statutory threshold and a fresh decision after hearing.
Approval under section 80G cannot be denied merely because a trust deed contains religious objects or some religious activity is shown, since section 80G(5B) permits religious expenditure up to five per cent of total income in the relevant previous year. Rejection based only on the religious nature of the objects and activities, without a finding that the statutory limit was exceeded, is unsustainable. The matter was set aside and remanded for a categorical finding on the statutory threshold and a fresh decision after hearing.
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