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...
Omission of specific wording in Form No.10 does not automatically defeat accumulation under section 11(2) where the assessee substantiates the specific purpose and the tax officer was aware of and did not disbelieve the declaration; accumulation must, however, remain within the trust's objects, and supporting documents (object clauses, board resolution, project details) may cure a vague Form 10 description. Tribunal directed fresh consideration of the deduction claimed under section 11(2) for the relevant year in light of the materials furnished and precedents favouring substance over formal vagueness.
Omission of specific wording in Form No.10 does not automatically defeat accumulation under section 11(2) where the assessee substantiates the specific purpose and the tax officer was aware of and did not disbelieve the declaration; accumulation must, however, remain within the trust's objects, and supporting documents (object clauses, board resolution, project details) may cure a vague Form 10 description. Tribunal directed fresh consideration of the deduction claimed under section 11(2) for the relevant year in light of the materials furnished and precedents favouring substance over formal vagueness.
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