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Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
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Statutory accumulation of 15 per cent of charitable income under section 11(1)(a) is distinct from further accumulation under section 11(2). Where charitable eligibility and application of income to charitable objects are satisfied, the statutory retention remains available. Accumulation beyond that limit may be claimed where Form No. 10 is furnished by the extended due date for filing the return, rather than only by the original due date. Charitable exemption should not be denied solely because Form No. 10BB was electronically furnished late if the audit report was available before return processing and substantive exemption conditions were met.
Statutory accumulation of 15 per cent of charitable income under section 11(1)(a) is distinct from further accumulation under section 11(2). Where charitable eligibility and application of income to charitable objects are satisfied, the statutory retention remains available. Accumulation beyond that limit may be claimed where Form No. 10 is furnished by the extended due date for filing the return, rather than only by the original due date. Charitable exemption should not be denied solely because Form No. 10BB was electronically furnished late if the audit report was available before return processing and substantive exemption conditions were met.
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