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...
Exemption u/s 11 - Once it is to be held that the assessee is a charitable institution and it is entitled for benefit u/s 11 and 12, then all other aspects of section 11(5) and 13(1)(d) etc are to be considered afresh. Somehow, it appears that the ld.AO failed to comprehend or concur with the higher appellate authorities about the status of the assessee being held as charitable institution, which is entitled for the benefit of section 11 and 12. - AT
Exemption u/s 11 - Once it is to be held that the assessee is a charitable institution and it is entitled for benefit u/s 11 and 12, then all other aspects of section 11(5) and 13(1)(d) etc are to be considered afresh. Somehow, it appears that the ld.AO failed to comprehend or concur with the higher appellate authorities about the status of the assessee being held as charitable institution, which is entitled for the benefit of section 11 and 12. - AT
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