Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
Principal Commissioner's transfer of the assessee's PAN and associated 'case' to the Central charge carried all powers over the PAN, including power to cancel registration; therefore PCIT(C) had jurisdiction to cancel registration for prior and subsequent years. Cancellation under registration provisions was upheld on merits: the trust's recorded activities were non genuine and deviated from its objects by funding profit entities, promoting partisan content, and making payments without evidence of services, amounting to specified violations; such use of funds defeats charitable application and justifies loss of exemption. The appeal against cancellation is dismissed.
Principal Commissioner's transfer of the assessee's PAN and associated 'case' to the Central charge carried all powers over the PAN, including power to cancel registration; therefore PCIT(C) had jurisdiction to cancel registration for prior and subsequent years. Cancellation under registration provisions was upheld on merits: the trust's recorded activities were non genuine and deviated from its objects by funding profit entities, promoting partisan content, and making payments without evidence of services, amounting to specified violations; such use of funds defeats charitable application and justifies loss of exemption. The appeal against cancellation is dismissed.
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