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...
When a registered charitable trust disclosed receipts under "income from other sources," denial of exemption was unwarranted because assessing authorities must apply a judicious approach and grant exemptions or deductions to which the assessee is entitled; appellate authorities are empowered and obligated to correct AO errors and may entertain reliefs not claimed in the return, with supporting precedents and administrative guidance cited. The failure of the AO, CIT(A) and Tribunal to consider merits resulted in reversal of the adverse outcome and payment of costs against the revenue, restoring the trust's entitlement to the claimed exemption.
When a registered charitable trust disclosed receipts under "income from other sources," denial of exemption was unwarranted because assessing authorities must apply a judicious approach and grant exemptions or deductions to which the assessee is entitled; appellate authorities are empowered and obligated to correct AO errors and may entertain reliefs not claimed in the return, with supporting precedents and administrative guidance cited. The failure of the AO, CIT(A) and Tribunal to consider merits resulted in reversal of the adverse outcome and payment of costs against the revenue, restoring the trust's entitlement to the claimed exemption.
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