Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Cash deposits during demonetisation were accepted as explained where recorded sales, stock details, VAT returns and cash-in-hand records supported the books; the estimated gross profit addition failed because the books were rejected without specific defects, and the material showed stock-backed sales rather than suspicion. The Tribunal also held that M/s. Jain Bullion belonged to its proprietor, not the assessee, since the relevant bank accounts were operated by the proprietor and the concern had separately conducted business and filed returns. Separately, the notional annual letting value addition in search assessment was deleted because no incriminating material for that item was found during the search.
Cash deposits during demonetisation were accepted as explained where recorded sales, stock details, VAT returns and cash-in-hand records supported the books; the estimated gross profit addition failed because the books were rejected without specific defects, and the material showed stock-backed sales rather than suspicion. The Tribunal also held that M/s. Jain Bullion belonged to its proprietor, not the assessee, since the relevant bank accounts were operated by the proprietor and the concern had separately conducted business and filed returns. Separately, the notional annual letting value addition in search assessment was deleted because no incriminating material for that item was found during the search.
Note: It is a system-generated summary and is for quick reference only.