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...
Interest income under the mercantile system was held taxable in AY 2007-08 on accrual basis because the assessee, having followed that method, had to bring the entire accrued amount to tax in that year and produced no corroborative material showing that accrual had been deferred by litigation or other valid reason. The Tribunal also upheld reopening under section 147, holding that the original assessment had not examined the balance accrued interest and that information from remand proceedings constituted tangible material; the plea of mere change of opinion therefore failed. To avoid double taxation, it approved verification and rectification in AY 2009-10 if the amount had been declared there.
Interest income under the mercantile system was held taxable in AY 2007-08 on accrual basis because the assessee, having followed that method, had to bring the entire accrued amount to tax in that year and produced no corroborative material showing that accrual had been deferred by litigation or other valid reason. The Tribunal also upheld reopening under section 147, holding that the original assessment had not examined the balance accrued interest and that information from remand proceedings constituted tangible material; the plea of mere change of opinion therefore failed. To avoid double taxation, it approved verification and rectification in AY 2009-10 if the amount had been declared there.
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