Belated Form 10B filing during Covid-19 cannot defeat charitable exemption where genuine hardship warrants condonation and substantial justice prevail...
Limitation for consequential assessments runs from prescribed authority receipt, while verified purchases cannot be disallowed merely for unanswered s...
Higher depreciation for qualifying commercial vehicles, exempt-income disallowance, research deduction verification, and club-expense treatment clarif...
Charitable registration renewal cannot become an assessment of receipts, profitability or annual exemption compliance, requiring renewal and donation ...
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On identical facts, the ITAT followed its earlier order and held that the Revenue had failed to establish any permanent establishment in India for the assessee in relation to offshore supply under the ONGC contract. As a result, the offshore supply receipts could not be taxed on a presumptive basis under section 44BB, and the addition was deleted. The Tribunal also noted that the DRP had found the facts unchanged from earlier years; interest and penalty grounds were treated as consequential.
On identical facts, the ITAT followed its earlier order and held that the Revenue had failed to establish any permanent establishment in India for the assessee in relation to offshore supply under the ONGC contract. As a result, the offshore supply receipts could not be taxed on a presumptive basis under section 44BB, and the addition was deleted. The Tribunal also noted that the DRP had found the facts unchanged from earlier years; interest and penalty grounds were treated as consequential.
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