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...
Rejection of application filed in form no. 10AB for grant of registration u/s 12AB and 80G(5) - The ITAT found that the CIT(E) had grounds for dissatisfaction based on the deficiencies and non-compliances reported by the CAG. However, the material effect of these issues on the Assessee's objectives was not explicitly addressed. The matter was remanded to the CIT(E) for a detailed examination and to provide a reasoned decision on whether these issues affect the Assessee's eligibility for registration under sections 12AB and 80G.
Rejection of application filed in form no. 10AB for grant of registration u/s 12AB and 80G(5) - The ITAT found that the CIT(E) had grounds for dissatisfaction based on the deficiencies and non-compliances reported by the CAG. However, the material effect of these issues on the Assessee's objectives was not explicitly addressed. The matter was remanded to the CIT(E) for a detailed examination and to provide a reasoned decision on whether these issues affect the Assessee's eligibility for registration under sections 12AB and 80G.
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