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...
A CBDT-prescribed format defect in notice under section 143(2) was held to be only a technical irregularity and not, by itself, a ground to invalidate the assessment. The rejection of books under section 145(3) was found unjustified because specific reasons for such rejection were not properly established, although the cash-book discrepancies could still be examined for a separate addition under section 69A. On the cash-deposit issue, the matter was remanded for de novo assessment so the assessee could produce supporting evidence and the Assessing Officer could decide the source of deposits afresh after affording effective hearing.
A CBDT-prescribed format defect in notice under section 143(2) was held to be only a technical irregularity and not, by itself, a ground to invalidate the assessment. The rejection of books under section 145(3) was found unjustified because specific reasons for such rejection were not properly established, although the cash-book discrepancies could still be examined for a separate addition under section 69A. On the cash-deposit issue, the matter was remanded for de novo assessment so the assessee could produce supporting evidence and the Assessing Officer could decide the source of deposits afresh after affording effective hearing.
Note: It is a system-generated summary and is for quick reference only.