Income-tax prosecution fails when appellate remand removes its factual foundation; directors require company arraignment for vicarious criminal liabil...
Capital character of assignment consideration prevents taxation as residuary income, while unsupported interest-related expenditure remains non-deduct...
Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exi...
Transfer-pricing treatment of corporate guarantees and convertible loans followed prior-year consistency, with taxable foreign dividends excluded from...
Transfer-pricing benchmarking confines adjustments to associated-enterprise transactions and integrates delayed receivables through TNMM working-capit...
Medical relief status protects government-contracted mobile healthcare from commercial classification, while provisional registration cancellation req...
Charitable registration cancellation requires proof that educational activities abandoned their objects; incidental receipts and retained surplus are ...
Section 80G(5)(i) treats non-inclusion of income under sections 11 and 12, or under section 10(23C), as alternative conditions for approval. An educational institution claiming exemption under section 10(23C)(iiiad) need not also hold registration under section 12AB solely to satisfy the approval requirement. The competent authority must examine whether the institution is covered by section 10(23C)(iiiad) and cannot reject its section 80G application only because section 12AB registration is absent. Approval remains subject to verification of the claimed statutory coverage.
Section 80G(5)(i) treats non-inclusion of income under sections 11 and 12, or under section 10(23C), as alternative conditions for approval. An educational institution claiming exemption under section 10(23C)(iiiad) need not also hold registration under section 12AB solely to satisfy the approval requirement. The competent authority must examine whether the institution is covered by section 10(23C)(iiiad) and cannot reject its section 80G application only because section 12AB registration is absent. Approval remains subject to verification of the claimed statutory coverage.
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TaxTMI 
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