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...
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
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4878 
