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...
Whether incriminating material seized in search sustains additions under section 153A - tribunal, following Benefit Tradelink, finds the issue against the assessee and dismisses the ground challenging additions. Addition as income under section 56(2)(vi) for amounts received as student fees - since receipts were offered to tax before the Settlement Commission and constituted student fees, section 56(2)(vi) is not attracted and no addition is warranted. Unexplained investment in property - pro rata contribution recomputed and limited to Rs.1,42,000, ground partly allowed. Purchase of specified land - amounts already offered before the Settlement Commission; no further addition. Stamp duty/registration expenses paid by relatives and not offered earlier - Revenue free to tax those amounts. - ITAT
Whether incriminating material seized in search sustains additions under section 153A - tribunal, following Benefit Tradelink, finds the issue against the assessee and dismisses the ground challenging additions. Addition as income under section 56(2)(vi) for amounts received as student fees - since receipts were offered to tax before the Settlement Commission and constituted student fees, section 56(2)(vi) is not attracted and no addition is warranted. Unexplained investment in property - pro rata contribution recomputed and limited to Rs.1,42,000, ground partly allowed. Purchase of specified land - amounts already offered before the Settlement Commission; no further addition. Stamp duty/registration expenses paid by relatives and not offered earlier - Revenue free to tax those amounts. - ITAT
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