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 10(23C)(vi) - scope of the term "Education" - no specific definition for "education" under the Income Tax Act of 1961 - assisting Banking Institutions in the matters such as appraisal programmes, conducting morale and productivity studies etc., also fall within the category of education. It is not in dispute that the assessee is a Staff Training College for Bank employees. Therefore, in our considered view, assessee must be construed as an Educational Institution because the main object is to train the Bank Officials. - HC
Exemption u/s 10(23C)(vi) - scope of the term "Education" - no specific definition for "education" under the Income Tax Act of 1961 - assisting Banking Institutions in the matters such as appraisal programmes, conducting morale and productivity studies etc., also fall within the category of education. It is not in dispute that the assessee is a Staff Training College for Bank employees. Therefore, in our considered view, assessee must be construed as an Educational Institution because the main object is to train the Bank Officials. - HC
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