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...
WhatsApp images, standing alone, were held insufficient to sustain additions for alleged cash salary and bonus payments because they did not identify the nature of the entries, and no corroborative evidence of actual cash disbursement was produced; the additions were deleted. In the stock matter, the alleged shortage during survey failed because silo stock was not properly quantified, the verification exercise was materially deficient, and later reconciliation and supporting records were not effectively examined; the consequent addition by applying a gross profit rate on presumed unaccounted sales was also deleted. The assessee's appeals were partly allowed and the Revenue's challenge failed.
WhatsApp images, standing alone, were held insufficient to sustain additions for alleged cash salary and bonus payments because they did not identify the nature of the entries, and no corroborative evidence of actual cash disbursement was produced; the additions were deleted. In the stock matter, the alleged shortage during survey failed because silo stock was not properly quantified, the verification exercise was materially deficient, and later reconciliation and supporting records were not effectively examined; the consequent addition by applying a gross profit rate on presumed unaccounted sales was also deleted. The assessee's appeals were partly allowed and the Revenue's challenge failed.
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