Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
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The case pertains to the refusal of registration u/s 12AA for charitable activities u/s 2(15). The Commissioner of Income Tax observed that the society was not imparting education as a charitable purpose within the meaning of Section 2(15), despite being granted approval u/s 10(23)(vi). The court held that the powers to cancel registration u/s 12AA(3) can only be applied prospectively, not retrospectively, as per precedents. Since the institute is a registered educational trust and utilizes earnings for education, it cannot be denied registration u/s 12AA. The High Court dismissed the appeal, finding no error by the Income Tax Appellate Tribunal in granting registration u/s 12AA.
The case pertains to the refusal of registration u/s 12AA for charitable activities u/s 2(15). The Commissioner of Income Tax observed that the society was not imparting education as a charitable purpose within the meaning of Section 2(15), despite being granted approval u/s 10(23)(vi). The court held that the powers to cancel registration u/s 12AA(3) can only be applied prospectively, not retrospectively, as per precedents. Since the institute is a registered educational trust and utilizes earnings for education, it cannot be denied registration u/s 12AA. The High Court dismissed the appeal, finding no error by the Income Tax Appellate Tribunal in granting registration u/s 12AA.
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