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...
A show cause notice for cancellation of charitable trust registration was valid where it referred to the search, survey, violations of the trust deed, misuse of the trust, and assessment findings; the trust's detailed reply showed adequate notice and opportunity to respond, and the Tribunal erred in treating the allegations as vague or isolating the Managing Trustee's conduct from the trust's misuse. The Court also held that the amended power to cancel registration could be invoked against a trust registered earlier, but the cancellation could not operate retrospectively from the original date of registration. The cancellation was upheld, but confined to the date of the cancellation order.
A show cause notice for cancellation of charitable trust registration was valid where it referred to the search, survey, violations of the trust deed, misuse of the trust, and assessment findings; the trust's detailed reply showed adequate notice and opportunity to respond, and the Tribunal erred in treating the allegations as vague or isolating the Managing Trustee's conduct from the trust's misuse. The Court also held that the amended power to cancel registration could be invoked against a trust registered earlier, but the cancellation could not operate retrospectively from the original date of registration. The cancellation was upheld, but confined to the date of the cancellation order.
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