Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
The ITAT held that the approval under section 151 without a valid manual or digital signature is invalid, rendering the subsequent notice under section 148 void for lack of jurisdiction; thus, the reassessment order under section 143(3) read with section 147 was quashed. The issuance of notice under section 148 by a JAO was upheld as valid under the faceless regime. Income from sale of scrap was held to be business income, not unexplained cash under section 69A, and the estimated additions on this account were partly deleted, with the profit estimated using the PBT percentage from regular books. Out-of-books expenses disallowance under section 69C was deleted. Bogus salary and professional fees disallowance under section 37(1) was reversed. Certain estimated disallowances were sustained. Additions based on diary entries were largely disallowed due to inadequate proof of unexplained income. Business promotion expenses were fully allowed as wholly and exclusively incurred for business.
The ITAT held that the approval under section 151 without a valid manual or digital signature is invalid, rendering the subsequent notice under section 148 void for lack of jurisdiction; thus, the reassessment order under section 143(3) read with section 147 was quashed. The issuance of notice under section 148 by a JAO was upheld as valid under the faceless regime. Income from sale of scrap was held to be business income, not unexplained cash under section 69A, and the estimated additions on this account were partly deleted, with the profit estimated using the PBT percentage from regular books. Out-of-books expenses disallowance under section 69C was deleted. Bogus salary and professional fees disallowance under section 37(1) was reversed. Certain estimated disallowances were sustained. Additions based on diary entries were largely disallowed due to inadequate proof of unexplained income. Business promotion expenses were fully allowed as wholly and exclusively incurred for business.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4878 
