“Section 2(15)(ii)”

A provision for doubtful debts cannot be added back while computing book profits under Section 115JB of the Income-tax Act for Minimum Alternate Tax (MAT) purposes.

Salary received by a non-resident for services rendered outside India accrues outside India and is not taxable in India. Only salary earned for work performed in India is regarded as income arising in India and is taxable.

Charging fees, even when having regard to the economic status of beneficiaries, is permissible for the sustenance of charitable activities, provided it is necessary for operation and running expenses and does not amount to carrying on trade or commerce. This applies even after the introduction of the proviso to Section 2(15) of the Income Tax Act, 1961.

The proviso to section 2(15) should not be invoked to deny exemption to a sports organization if its activities are not predominantly in the nature of trade, commerce, or business.

A decision by the Gujarat High Court in CIT v. C-Sam (India) Pvt Ltd. does not support the case of a party relying on it, particularly when other High Courts have made contrary findings.

An institution or fund is deemed to be one to which section 80G applies even if it incurs expenditure of a religious nature not exceeding five per cent. of its total income, overriding Explanation 3 to section 80G(5)(ii).

The definition of 'eligible assessee' under section 144C(15)(b) delineates two distinct categories of persons, rather than imposing two conditions.

Decisions holding that an assessee does not exist for a charitable purpose are not applicable if the issue involved in those cases pertains to cancellation of registration under section 12A of the Income-tax Act.