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...
Deduction under section 35(1)(ii) was denied because the recipient trust lacked valid recognition beyond 31.03.2006 and post 2006 certificates/receipts were treated as forged or invalid; ITAT upheld disallowance, endorsing the Commissioner(Appeals) reliance on CBDT instructions and precedent. Separately, weighted deductions under section 80 IA for an effluent treatment plant and steam generation were refused for failure to furnish the statutory audit report/Form 10CCB within the prescribed period; ITAT applied the principle of strict/substantial compliance of fiscal formalities and held the conditions precedent unmet, so deductions could not be allowed. Appeals dismissed on both grounds.
Deduction under section 35(1)(ii) was denied because the recipient trust lacked valid recognition beyond 31.03.2006 and post 2006 certificates/receipts were treated as forged or invalid; ITAT upheld disallowance, endorsing the Commissioner(Appeals) reliance on CBDT instructions and precedent. Separately, weighted deductions under section 80 IA for an effluent treatment plant and steam generation were refused for failure to furnish the statutory audit report/Form 10CCB within the prescribed period; ITAT applied the principle of strict/substantial compliance of fiscal formalities and held the conditions precedent unmet, so deductions could not be allowed. Appeals dismissed on both grounds.
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