article of association contains
the internal procedure and powers and functions of various functionaries of
society to achieve the main object of the society
appellant entity are
distinct. Accordingly, the functionaries of Indian entity at
local level are equipped to handle the functions performed
at local level in India
othe r functionary imple menting
statute o r law whether implementing judicial functions or an
administrative functions is a judicial authority with regard
survey, from the statement of various functionaries
recorded and the documents inspected, it was noticed that many
important functions of the businesses of Genpact group
assessee company Key components of
work were performed by these senior functionaries of the
assessee from premises of the subsidiary of the assessee
in India ... these executives
of the assessee form a part of the core functions of the
assessee. Thus a significant chunk of the core functioning
administration are functionaries of "the State" exist for "the State" and perform
the functions of "the State". For this
suggest changes
therein which may be desirable and feasible:
(i) Board level functionaries
(ii) Below Board level executives
(iii) Non-unionized supervisory staff ... 6151/Del/2014.
Housing & Urban Development Corporation Ltd.
as promoting functional and operational autonomy within the Public Sector
Enterprises with a view to leveraging
K. Narsimha, New Delhi vs Assessee on 26 March, 2015
IN THE INCOME TAX APPELLATE
assessment order."
9. The AO has not appreciated the functioning of the society and the
requirement of the law in the right perspective ... observed that
people who are related through blood cannot be functionaries of the society.
This interpretation of the law by the AO is not correct
assessment order. "
9. The AO has not appreciated the functioning of the society and
the requirement of the law in the right perspective ... observed that people who are related through blood cannot be
functionaries of the society. This interpretation of the law by the
AO is not correct