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...
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Cancellation of registration granted u/s 12AB - Assessment of trust - The ITAT held that the PCIT's order to cancel the registration from the financial year 2020-21 and subsequent years under section 12AB(4)(ii) was beyond his jurisdiction, particularly for the assessment year 2021-22, as the provision was not applicable retrospectively. - The Tribunal clarified that the law applicable to an assessment year should be the law in force for that year unless specified otherwise.
Cancellation of registration granted u/s 12AB - Assessment of trust - The ITAT held that the PCIT's order to cancel the registration from the financial year 2020-21 and subsequent years under section 12AB(4)(ii) was beyond his jurisdiction, particularly for the assessment year 2021-22, as the provision was not applicable retrospectively. - The Tribunal clarified that the law applicable to an assessment year should be the law in force for that year unless specified otherwise.
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