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...
Revision u/s 263 by CIT - direction to the AO to compute income of the appellant Trust without allowing exemption u/s. 10(23C)(iiiae) - All the conditions as prescribed u/s.10(23C)(iiiae) of the Act, have been fulfilled by the appellant Trust and there is no allegation that the appellant Trust is involved in any other activity for profit or does not exist for philanthropic purposes. Even in this case, all the facts are on the file, therefore there was no need for any further investigation by the A.O. as alleged by the Ld. CIT(E). - AT
Revision u/s 263 by CIT - direction to the AO to compute income of the appellant Trust without allowing exemption u/s. 10(23C)(iiiae) - All the conditions as prescribed u/s.10(23C)(iiiae) of the Act, have been fulfilled by the appellant Trust and there is no allegation that the appellant Trust is involved in any other activity for profit or does not exist for philanthropic purposes. Even in this case, all the facts are on the file, therefore there was no need for any further investigation by the A.O. as alleged by the Ld. CIT(E). - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4878 
