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...
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Section 41(1) did not apply where funds received from an AOP were credited to the assessee's personal bank account and later introduced into the business as capital. The ITAT noted that the Assessing Officer had treated the receipt as cessation of liability merely because it was not reflected in the proprietary concern's books, but the account confirmation, bank statement and debit balance with the AOP showed that the amount was received in the assessee's personal capacity. As the essential condition of cessation of liability was absent, the addition under Section 41(1) was unsustainable and was deleted.
Section 41(1) did not apply where funds received from an AOP were credited to the assessee's personal bank account and later introduced into the business as capital. The ITAT noted that the Assessing Officer had treated the receipt as cessation of liability merely because it was not reflected in the proprietary concern's books, but the account confirmation, bank statement and debit balance with the AOP showed that the amount was received in the assessee's personal capacity. As the essential condition of cessation of liability was absent, the addition under Section 41(1) was unsustainable and was deleted.
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