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...
Issue 1 - Unexplained investment under section 69A: tribunal found ledger and monthly summaries of proprietor's drawings (narrating cash withdrawals used to purchase the site) constituted prima facie source for the cash payments, though these records were not produced before the AO; consequence: matter remitted to the AO to consider the documents filed before the tribunal (and any further evidence) and decide in accordance with law after hearing the assessee. Issue 2 - Net-profit determination: AO's adoption of 8% standard profit was unsupported, whereas audited books and industry comparables justified the declared 7% margin; consequence: addition confirmed by lower authorities set aside and appeal allowed. - ITAT
Issue 1 - Unexplained investment under section 69A: tribunal found ledger and monthly summaries of proprietor's drawings (narrating cash withdrawals used to purchase the site) constituted prima facie source for the cash payments, though these records were not produced before the AO; consequence: matter remitted to the AO to consider the documents filed before the tribunal (and any further evidence) and decide in accordance with law after hearing the assessee. Issue 2 - Net-profit determination: AO's adoption of 8% standard profit was unsupported, whereas audited books and industry comparables justified the declared 7% margin; consequence: addition confirmed by lower authorities set aside and appeal allowed. - ITAT
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