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...
ITAT reviewed cancellation of a charitable institution's registration under 10(23C)(vi) and found the cancellation relied on unverified adverse inferences from minor discrepancies rather than a proper enquiry; the tribunal held that issues like duplicate receipts, advance land payments, lease-versus-asset characterisation and small expenditures required detailed scrutiny or assessment (including examination under provisions governing inurement) rather than summary revocation. Applying the proviso and Explanation 2, the recorded reasons did not establish satisfaction of specified violations prior to cancellation; the cancellation order was set aside and registration restored.
ITAT reviewed cancellation of a charitable institution's registration under 10(23C)(vi) and found the cancellation relied on unverified adverse inferences from minor discrepancies rather than a proper enquiry; the tribunal held that issues like duplicate receipts, advance land payments, lease-versus-asset characterisation and small expenditures required detailed scrutiny or assessment (including examination under provisions governing inurement) rather than summary revocation. Applying the proviso and Explanation 2, the recorded reasons did not establish satisfaction of specified violations prior to cancellation; the cancellation order was set aside and registration restored.
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