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Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
Section 13(1)(b)'s restriction on trusts benefiting a particular religious community applies when exemption under section 11 is considered, rather than at the section 12A registration stage. A trust whose objects are largely charitable and directed to the public at large is not disqualified merely because its objects include services to pilgrims and religious places. Where the trust is not established wholly for a particular religious community, its application for approval under section 80G(5) requires fresh consideration after verification and an opportunity of hearing. No substantial question of law arose from the Tribunal's direction for such reconsideration.
Section 13(1)(b)'s restriction on trusts benefiting a particular religious community applies when exemption under section 11 is considered, rather than at the section 12A registration stage. A trust whose objects are largely charitable and directed to the public at large is not disqualified merely because its objects include services to pilgrims and religious places. Where the trust is not established wholly for a particular religious community, its application for approval under section 80G(5) requires fresh consideration after verification and an opportunity of hearing. No substantial question of law arose from the Tribunal's direction for such reconsideration.
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