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Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
The ITAT held that the trust's case falls outside the scope of Section 13(1)(c)(ii) as no portion of its income was applied for the benefit of any specific person. Despite erroneous presentation in Form No. 10B and an amount appearing as advance to SCPL, which was reimbursement of expenses, the trust did not divert income or provide undue benefits to the related party. The CIT(A) correctly analyzed the facts, and the ITAT upheld the order in favor of the assessee, allowing exemption u/s 11.
The ITAT held that the trust's case falls outside the scope of Section 13(1)(c)(ii) as no portion of its income was applied for the benefit of any specific person. Despite erroneous presentation in Form No. 10B and an amount appearing as advance to SCPL, which was reimbursement of expenses, the trust did not divert income or provide undue benefits to the related party. The CIT(A) correctly analyzed the facts, and the ITAT upheld the order in favor of the assessee, allowing exemption u/s 11.
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TaxTMI 
TaxTMI 
