Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
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.
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