Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
Timely furnishing of Form No. 10B within an extended return-filing deadline satisfies the audit-report requirement for charitable-trust exemption. Although filing the audit report is a substantive requirement, the prescribed timing and mode of submission are procedural where the report is available before assessment. Rejection of a condonation application does not bar the exemption because condonation is an additional remedy. Form No. 10B for the relevant assessment year must therefore be accepted and the claimed exemption granted.
Timely furnishing of Form No. 10B within an extended return-filing deadline satisfies the audit-report requirement for charitable-trust exemption. Although filing the audit report is a substantive requirement, the prescribed timing and mode of submission are procedural where the report is available before assessment. Rejection of a condonation application does not bar the exemption because condonation is an additional remedy. Form No. 10B for the relevant assessment year must therefore be accepted and the claimed exemption granted.
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