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...
Penalty under s.270A for "underreporting of income" was challenged on the ground that the assessed addition was made on an estimated basis by lump-sum disallowance of expenses. The Tribunal held that estimated additions are excluded under s.270A(6) only where the accounts are found correct and complete but income cannot be properly deduced from the method employed; here the AO recorded that the books were not correct and complete due to discrepancies and unsupported vouchers, which remained unrebutted, hence penalty was sustainable. Penalty on disallowance under s.40(a)(ia) for TDS default was also upheld as no contrary submissions were made; appeal was dismissed. - ITAT
Penalty under s.270A for "underreporting of income" was challenged on the ground that the assessed addition was made on an estimated basis by lump-sum disallowance of expenses. The Tribunal held that estimated additions are excluded under s.270A(6) only where the accounts are found correct and complete but income cannot be properly deduced from the method employed; here the AO recorded that the books were not correct and complete due to discrepancies and unsupported vouchers, which remained unrebutted, hence penalty was sustainable. Penalty on disallowance under s.40(a)(ia) for TDS default was also upheld as no contrary submissions were made; appeal was dismissed. - ITAT
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