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...
Addition under section 40A(3) challenged on facts showing freight payments were not made in cash to a single driver exceeding the statutory limit, and the appellate authority found records and affidavits supporting that payments were direct to drivers, resulting in deletion of the addition. Addition for alleged unrecorded cash payment based on mobile messages was deleted because the messages were unauthenticated, no verification or enquiry was made of the purported recipients, books were not rejected, and there was no corroborative evidence, leading to deletion.
Addition under section 40A(3) challenged on facts showing freight payments were not made in cash to a single driver exceeding the statutory limit, and the appellate authority found records and affidavits supporting that payments were direct to drivers, resulting in deletion of the addition. Addition for alleged unrecorded cash payment based on mobile messages was deleted because the messages were unauthenticated, no verification or enquiry was made of the purported recipients, books were not rejected, and there was no corroborative evidence, leading to deletion.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4819 
Join Channel 
