Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
Reopening under s.147 was held invalid because the recorded reasons did not demonstrate a clear, direct nexus between the stated transaction discrepancies and any escapement of income, rendering the belief speculative; accordingly, the reassessment was quashed. Independently, the s.68 addition for alleged unexplained credits was deleted as the taxpayer discharged the statutory onus by furnishing cogent documentary evidence establishing identity, creditworthiness, and genuineness of the credit, and the loan was also repaid; the appellate confirmation of the addition was set aside. - ITAT
Reopening under s.147 was held invalid because the recorded reasons did not demonstrate a clear, direct nexus between the stated transaction discrepancies and any escapement of income, rendering the belief speculative; accordingly, the reassessment was quashed. Independently, the s.68 addition for alleged unexplained credits was deleted as the taxpayer discharged the statutory onus by furnishing cogent documentary evidence establishing identity, creditworthiness, and genuineness of the credit, and the loan was also repaid; the appellate confirmation of the addition was set aside. - ITAT
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