Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Renewal of charitable registration under section 12A(1)(ac)(ii) had to be decided by the Commissioner of Income-tax (Exemptions), and transfer of PAN or assessment jurisdiction did not confer subject-matter jurisdiction on the Principal Commissioner (Central); the impugned rejection was therefore without jurisdiction. On merits, the renewal enquiry was confined to genuineness of activities and compliance with allied laws, and could not be expanded into cancellation-style allegations under section 12AB(4). Search-period material, minor irregularities, and Settlement Commission observations did not justify denial where education activity was otherwise accepted. The Tribunal directed renewal of registration and issue of the certificate.
Renewal of charitable registration under section 12A(1)(ac)(ii) had to be decided by the Commissioner of Income-tax (Exemptions), and transfer of PAN or assessment jurisdiction did not confer subject-matter jurisdiction on the Principal Commissioner (Central); the impugned rejection was therefore without jurisdiction. On merits, the renewal enquiry was confined to genuineness of activities and compliance with allied laws, and could not be expanded into cancellation-style allegations under section 12AB(4). Search-period material, minor irregularities, and Settlement Commission observations did not justify denial where education activity was otherwise accepted. The Tribunal directed renewal of registration and issue of the certificate.
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