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...
In a limited scrutiny selected only to examine share premium, the AO made an addition u/s 68 for unexplained cash credit relating to share application money, thereby travelling beyond the permitted scope; the addition and consequential assessment were held unsustainable and the assessment was quashed as nullity. Separately, the statutory notice u/s 143(2) was issued by one jurisdictional officer, but the assessment was completed by a different officer without a valid notice foundation; the assessment was held without jurisdiction and void ab initio, and was quashed. - ITAT
In a limited scrutiny selected only to examine share premium, the AO made an addition u/s 68 for unexplained cash credit relating to share application money, thereby travelling beyond the permitted scope; the addition and consequential assessment were held unsustainable and the assessment was quashed as nullity. Separately, the statutory notice u/s 143(2) was issued by one jurisdictional officer, but the assessment was completed by a different officer without a valid notice foundation; the assessment was held without jurisdiction and void ab initio, and was quashed. - ITAT
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