Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Periodic charitable-registration renewal under Form 10AB is described as a limited enquiry into the genuineness of activities and compliance with material laws for achieving charitable objects. The notes state that, under the periodic-registration regime and Rule 17A(2)(g), scrutiny for renewal is confined to the immediately preceding three financial years for which registration was held under the new regime. Material, financials or allegations relating to pre-1 April 2021 periods cannot be called for or relied upon to reject renewal. The discussion also states that unexamined responses and evidence, reliance on retracted statements or unrelated third-party material, and failure to identify current non-genuine activities do not support rejection. Registration and consequential approval were directed to be granted.
Periodic charitable-registration renewal under Form 10AB is described as a limited enquiry into the genuineness of activities and compliance with material laws for achieving charitable objects. The notes state that, under the periodic-registration regime and Rule 17A(2)(g), scrutiny for renewal is confined to the immediately preceding three financial years for which registration was held under the new regime. Material, financials or allegations relating to pre-1 April 2021 periods cannot be called for or relied upon to reject renewal. The discussion also states that unexamined responses and evidence, reliance on retracted statements or unrelated third-party material, and failure to identify current non-genuine activities do not support rejection. Registration and consequential approval were directed to be granted.
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