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...
Bad debt deduction is allowable where the assessee has written off the dues in its accounts as irrecoverable; under the amended law, further proof that the debt had actually become irrecoverable is not required, and the Tribunal deleted the disallowance by following T.R.F. Ltd. Estimated business expense disallowance based on fixed percentages of transportation and vehicle-related es, without comparable material or a reasoned basis, was held arbitrary and unsustainable; the 10% addition was deleted. The assessee's appeal was allowed.
Bad debt deduction is allowable where the assessee has written off the dues in its accounts as irrecoverable; under the amended law, further proof that the debt had actually become irrecoverable is not required, and the Tribunal deleted the disallowance by following T.R.F. Ltd. Estimated business expense disallowance based on fixed percentages of transportation and vehicle-related es, without comparable material or a reasoned basis, was held arbitrary and unsustainable; the 10% addition was deleted. The assessee's appeal was allowed.
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