Permanent establishment rules limit source taxation to profits attributable to a fixed place, guiding cross border business taxation.
The Protocol revises residence and tie breaker rules, modernises the definition of permanent establishment including specified inclusions and exclusions and a six month rule for construction sites, and confines source taxation to profits attributable to a PE determined on an arm's length basis with allowed deductions for PE expenses. It also sets capped withholding rates and detailed rules for dividends, interest, royalties and technical fees, allocates capital taxation by situs or residence, and prescribes methods for elimination of double taxation and a mutual agreement procedure for resolving treaty application disputes.

Tax exemption notification under section 10(23C)(iv) confirms a trust's notified status for specified assessment years.
Notification under section 10(23C)(iv) recognizes Shri Sathya Sai Central Trust, Bombay as a notified entity for income-tax purposes, applying to the assessment years 1984-85 to 1986-87 and specifying the temporal scope of that recognition under the relevant statutory provision.

Approval under section 35D for preparation of feasibility and project reports and market surveys for assessees.
M/s. Chaturvedi & Company, Calcutta, is notified as an approved concern under section 35D to carry out preparation of feasibility reports, preparation of project reports, and conducting market surveys for assessees; notification No. S.O.4814 dated 23-8-1985 records the firm's address and states the approval is effective from 19-8-1985 to 18-8-1988.

Exemption notification under section 10(23C)(v) grants tax-exempt status to a trust for specified assessment years.
Notifies grant of tax exemption to Sri Venkatachalapathy Anna Chattiram Trust, Kapisthalam, Thanjavur District, under section 10(23C)(v) of the Income-tax Act, 1961 for the assessment years 1985-86 to 1987-88, identifying the trust by name and citing the official notification reference.

Research institution approval under tax provisions recognised, subject to separate research accounts and annual audited reporting.
Approval under section 35(1)(ii) is granted to Arvind Medical Research Foundation, Madurai, subject to conditions requiring maintenance of a separate account for scientific research receipts, annual returns of research activities to the prescribed authority in prescribed forms by the annual deadline, submission of audited annual accounts and balance sheet to the prescribed authority with copies to the Commissioner of Income-tax by the annual deadline, and advance application to the Central Board of Direct Taxes for extension before approval expiry.

Notification under section 10(23C)(iv): Institute notified for tax exemption purposes for specified assessment years.
The Central Government, exercising the power conferred by sub-clause (iv) of clause (23C) of section 10 of the Income-tax Act, notifies the Institute of Chartered Accountants of India for the purposes of that provision for the assessment years 1982 83 to 1984 85.

Tax exemption recognition under section 10(23C)(iv) confirmed for Associated Chambers of Commerce & Industry of India.
The Central Government notifies The Associated Chambers of Commerce & Industry of India for the purposes of the income-tax exemption provision under clause (iv) of clause 23C of section 10, specifying recognition limited to the stated assessment years and recording the official notification reference.

Research tax approval requires separate research accounts, annual returns, audited accounts, and timely renewal applications.
Approval is granted to the National Institute of Mental Health & Neuro Sciences, Bangalore, as an approved institution categorized as an Association for research-related tax purposes, subject to maintaining a separate account for scientific research, furnishing prescribed annual returns by 30 April, submitting audited accounts and balance-sheet copies to the prescribed authority and the Commissioner by 30 June, and applying for renewal to the Central Board of Direct Taxes at least three months before expiry.

Tax exemption notification under Section 10(23C)(v) recognises Mirza Agiari and Parsi Anjuman as eligible for specified assessment-period benefits.
The Central Government notifies Mirza Agiari and Parsi Anjuman, Jamnagar under sub-clause (v) of clause (23C) of section 10 of the Income-tax Act, recognising them for the purposes of that provision for the period covered by the specified assessment years and recording the notification number and date.

Charitable donation deduction: Sri Raja Rajeswara Temple notified as public place of worship enabling tax deduction eligibility.
The Central Government issued S.O.4675 dated 22-8-1985 notifying Sri Raja Rajeswara Temple, Taliparamba as a place of public worship of renown throughout the State of Kerala, thereby making it eligible for the tax treatment applicable to recognized religious institutions under the Income-tax Act.

Approval under section 35(1)(ii) - institutional recognition granted subject to research accounting, reporting and audit conditions.
Approval under section 35(1)(ii): Potash Research Institute of India is recognised as an Institution in other natural and applied sciences subject to conditions: maintain separate research accounts; furnish annual returns of scientific research by 30 April; submit audited annual accounts, income and expenditure statement and balance-sheet to the prescribed authority and the Commissioner of Income-tax by 30 June; and apply for extension three months before approval expiry, with late applications liable to rejection.

Customs Tariff amendment: government sets 2 September 1985 as the Act's commencement date by ministerial notification.
The Central Government, exercising its delegated authority to fix commencement, appoints 2 September 1985 as the date on which the Customs Tariff (Second Amendment) Act, 1982 shall come into force by ministerial notification issued by the Department of Revenue, Ministry of Finance.

Double taxation avoidance treaty allocates taxing rights, limits source taxation on dividends, interest, royalties; provides mutual agreement and information exchange.
The Convention allocates taxing rights between India and Kenya for residents, applies to income taxes (including substantially similar future taxes), and defines residence with tie breaker rules. Business profits are taxable in the State of residence unless attributable to a permanent establishment in the other State, with profits attributed on an arm's length/separate enterprise basis. Source taxation of dividends, interest, royalties and management/professional fees is limited by specified maximum withholding rates but yields to PE/fixed base connection. The treaty provides unilateral credit methods to eliminate double taxation, non discrimination protections, a mutual agreement procedure, and exchange of information safeguards.

Approval under section 35(1)(ii) grants research institution recognition subject to reporting, audited accounts, and renewal conditions.
Jai Research Foundation is approved as an institution under section 35(1)(ii) for scientific research subject to conditions: maintain a separate account for research receipts; furnish annual research returns by 30 April; submit audited annual accounts, income and expenditure statement and balance sheet to the prescribed authority and the Commissioner of Income tax by 30 June; and apply for extension three months before approval expiry, with late applications liable to rejection. The approval is effective for the period specified in the notification.

Institute name change: approval for the renamed health foundation is retained but restricted until March 31, 1986.
Substitution of the institute's name directs that "Asthma and Bronchitis Foundation of India" be read as "Asthma Bronchitis and Cancer Lung Foundation of India, New Delhi" in the earlier Income Tax notification; the approval granted is expressly restricted up to March 31, 1986.

Approval restriction under section 35(1)(ii): National Dairy Development Board's tax-exemption approval limited by government notification.
The central government notification restricts the approval granted to National Dairy Development Board, Anand under section 35(1)(ii) of the Income-tax Act, 1961 by imposing a terminal date of March 31, 1986, thereby converting earlier ministerial approvals into a time-limited entitlement issued by the Department of Revenue.

Research institution approval requires separate research accounts, annual returns, audited accounts, and timely renewal application.
Approval under section 35(1)(ii) is granted to Hyderabad Science Society, Hyderabad, as an "Association" for the stated financial year, subject to conditions: maintain separate accounts for research receipts; furnish annual returns of scientific research activities to the prescribed authority in specified forms by the annual deadline; submit audited annual accounts, total income and expenditure statements, and balance sheets to the prescribed authority and copies to the Commissioner of Income-tax by the stated deadline; and apply to the Central Board of Direct Taxes for extension of approval within the prescribed advance period before expiry.

Research-institution approval under section 35(1)(ii) requires separate research accounts, annual returns, audited accounts, and timely renewal.
Approval under section 35(1)(ii) recognises The Institute of Road Transport, Taramani, Madras as an approved institution in the category of an Association for tax recognition for scientific research, subject to maintaining separate research accounts, furnishing annual returns of research activities by 30 April, and submitting audited accounts, income and expenditure statements, and a balance sheet to the prescribed authority and the concerned commissioner by 30 June.

Research institution approval under section 35(1)(ii) imposes maintenance, annual reporting and audit obligations for tax recognition.
Approval is granted to the Indian Register of Shipping, Bombay, as an approved institution under clause (ii) of sub section (1) of section 35 of the Income tax Act for the period 1 4 1985 to 31 3 1986, conditional on maintaining a separate research account, furnishing annual research returns to the prescribed authority by 30 April, submitting audited annual accounts and balance sheet to the prescribed authority and Commissioner by 30 June, and applying for extension to the Central Board of Direct Taxes at least three months before expiry.

Approval under section 35(1)(ii) grants research institutions tax recognition subject to accounting, reporting and renewal compliance requirements.
Approval under section 35(1)(ii) recognises the Centre for Earth Science Studies, Trivandrum as an approved research institution conditioned on maintaining a separate account for research receipts, furnishing annual scientific-activity returns to the prescribed authority, submitting audited annual accounts and balance sheet to the authority and the tax commissioner, and applying for renewal in advance of approval expiry to avoid rejection.