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...
Grant of approval u/s. 80G(5) - denial of approval as application was not filed within six months from the date of grant of provisional approval - The Tribunal observed that the Act does not empower it to condone delays in such matters, unlike provisions for other sections. Citing legal precedents, it affirmed that without explicit statutory authority, delay condonation is not permissible. Consequently, the denial of approval u/s. 80G(5) by the ld. CIT, Exemption was upheld.
Grant of approval u/s. 80G(5) - denial of approval as application was not filed within six months from the date of grant of provisional approval - The Tribunal observed that the Act does not empower it to condone delays in such matters, unlike provisions for other sections. Citing legal precedents, it affirmed that without explicit statutory authority, delay condonation is not permissible. Consequently, the denial of approval u/s. 80G(5) by the ld. CIT, Exemption was upheld.
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