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 - AO by invoking proviso to Section 2(15) and denying the exemption - Receipts from business activities exceeded the threshold of Rs. 10 lakhs and Rs. 20 lakhs - The ITAT directed the AO to assess whether the assessee's main activity, for which it was granted Section 12A registration, itself constituted trade, commerce, or business, or if the activities were intrinsically linked to the advancement of its charitable object.
Exemption u/s 11 - AO by invoking proviso to Section 2(15) and denying the exemption - Receipts from business activities exceeded the threshold of Rs. 10 lakhs and Rs. 20 lakhs - The ITAT directed the AO to assess whether the assessee's main activity, for which it was granted Section 12A registration, itself constituted trade, commerce, or business, or if the activities were intrinsically linked to the advancement of its charitable object.
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