Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Statutory housing board functions directed at housing development and general public utility can retain charitable status despite receipts that resemble commercial activity. Charges collected while discharging statutory public functions do not, merely because of their commercial character, trigger the exclusion for trade, commerce or business under section 2(15) read with section 13(8). The housing board therefore remained eligible for income-tax exemption under sections 11 and 12, and the Revenue's challenge to that exemption failed.
Statutory housing board functions directed at housing development and general public utility can retain charitable status despite receipts that resemble commercial activity. Charges collected while discharging statutory public functions do not, merely because of their commercial character, trigger the exclusion for trade, commerce or business under section 2(15) read with section 13(8). The housing board therefore remained eligible for income-tax exemption under sections 11 and 12, and the Revenue's challenge to that exemption failed.
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