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 held that reference to a defined community in a trust's activities does not, by itself, negate charitable status where the overall objects and activities also benefit the general public. The Tribunal accepted that benefit to a limited class can still fall within public charity when the charitable purpose is not confined exclusively to that group. On that basis, the finding of specified violation under the Explanation to section 12AB(4) and the consequent cancellation of registration could not be sustained. The rejection and cancellation of registration were set aside and the appeal was allowed.
ITAT held that reference to a defined community in a trust's activities does not, by itself, negate charitable status where the overall objects and activities also benefit the general public. The Tribunal accepted that benefit to a limited class can still fall within public charity when the charitable purpose is not confined exclusively to that group. On that basis, the finding of specified violation under the Explanation to section 12AB(4) and the consequent cancellation of registration could not be sustained. The rejection and cancellation of registration were set aside and the appeal was allowed.
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