Effective service requirement: officers must explore alternative service modes beyond the GST portal and afford personal hearing; non-compliance voids...
Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
ITAT deleted the addition in the firm's hands for partners' capital contribution under section 68, holding that once the firm furnished the source of capital and the partners confirmed the contribution, its onus stood discharged; any further inquiry into creditworthiness had to be made against the partners, not the firm. On unsecured loans from two creditors, the Tribunal found the assessee's version of banking-channel receipts and later repayment with interest required verification of bank entries and repayment evidence. That issue was remanded to the Assessing Officer for fresh adjudication, with no addition indicated if repayment was established. The appeal was thus allowed for statistical purposes.
ITAT deleted the addition in the firm's hands for partners' capital contribution under section 68, holding that once the firm furnished the source of capital and the partners confirmed the contribution, its onus stood discharged; any further inquiry into creditworthiness had to be made against the partners, not the firm. On unsecured loans from two creditors, the Tribunal found the assessee's version of banking-channel receipts and later repayment with interest required verification of bank entries and repayment evidence. That issue was remanded to the Assessing Officer for fresh adjudication, with no addition indicated if repayment was established. The appeal was thus allowed for statistical purposes.
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