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Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
The Supreme Court held that the High Court should formulate the second substantial question of law proposed by the Revenue regarding whether violation of conditions u/s 13(1)(c) would result in denial of exemption on the whole income or be restricted to the income in violation of Section 13(1)(c). The Court directed the High Court to answer this question along with the already admitted question of law, without expressing any final opinion on the merits. The case pertained to the non-admission of a substantial question by the High Court and the deletion of addition made on account of cash donation collected outside the books of accounts by the Income Tax Appellate Tribunal.
The Supreme Court held that the High Court should formulate the second substantial question of law proposed by the Revenue regarding whether violation of conditions u/s 13(1)(c) would result in denial of exemption on the whole income or be restricted to the income in violation of Section 13(1)(c). The Court directed the High Court to answer this question along with the already admitted question of law, without expressing any final opinion on the merits. The case pertained to the non-admission of a substantial question by the High Court and the deletion of addition made on account of cash donation collected outside the books of accounts by the Income Tax Appellate Tribunal.
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TaxTMI 
TaxTMI 
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