Capital-gains exemption for charitable trusts extends to qualifying fixed deposits, while unrecoverable TDS write-offs may constitute income applicati...
India-UK treaty characterisation of telecom-service receipts as business profits withstands unilateral domestic-law amendments for Indian tax purposes...
Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
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Exemption u/s 11 denied - ssessee was not registered u/s 12AA - The activity of the assessee cannot be treated as business because the assessee had not rendered to any services to the entities from whom the payments are received. The concept of “diversion of income by overriding title” will also not be applicable in the case of the assessee because the amount collected by the assessee is for the purpose of the religious activities of the assessee and for such fund registration U/s. 12A is mandatory to claim the benefit U/s.11 of the Act. - AT
Exemption u/s 11 denied - ssessee was not registered u/s 12AA - The activity of the assessee cannot be treated as business because the assessee had not rendered to any services to the entities from whom the payments are received. The concept of “diversion of income by overriding title” will also not be applicable in the case of the assessee because the amount collected by the assessee is for the purpose of the religious activities of the assessee and for such fund registration U/s. 12A is mandatory to claim the benefit U/s.11 of the Act. - AT
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