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...
ITAT held that cash deposits in a small trader's bank account, including interest, could not again be assessed as unexplained income where they arose from retail trading receipts and profit had already been offered on those receipts. Accepting that the assessee dealt in agricultural produce and had disclosed presumptive profit at 5% on business turnover, the Tribunal applied the principle that once bank deposits are treated as turnover and taxed through estimated profit, the entire deposits cannot be added again. The addition made by the lower authority was deleted.
ITAT held that cash deposits in a small trader's bank account, including interest, could not again be assessed as unexplained income where they arose from retail trading receipts and profit had already been offered on those receipts. Accepting that the assessee dealt in agricultural produce and had disclosed presumptive profit at 5% on business turnover, the Tribunal applied the principle that once bank deposits are treated as turnover and taxed through estimated profit, the entire deposits cannot be added again. The addition made by the lower authority was deleted.
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