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...
Notional partners' capital entries credited as receivable under an LLP agreement were held outside section 68 because there was no actual inflow of funds during the year, the entries were only book adjustments, and the partners' identities and creditworthiness were not materially disputed; the addition was deleted. Administrative expenditure was also allowed because the LLP had already been set up through execution of the agreement, bank account opening, professional engagement, and regulatory steps, so business expenses remained deductible even without revenue. The Tribunal therefore upheld deletion of both the section 68 addition and the disallowance of administrative expenditure and dismissed the Revenue's appeal.
Notional partners' capital entries credited as receivable under an LLP agreement were held outside section 68 because there was no actual inflow of funds during the year, the entries were only book adjustments, and the partners' identities and creditworthiness were not materially disputed; the addition was deleted. Administrative expenditure was also allowed because the LLP had already been set up through execution of the agreement, bank account opening, professional engagement, and regulatory steps, so business expenses remained deductible even without revenue. The Tribunal therefore upheld deletion of both the section 68 addition and the disallowance of administrative expenditure and dismissed the Revenue's appeal.
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