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...
Dispute concerns revenue recognition where the assessing officer treated finished goods/advances as sales despite the assessee following the project completion method. The tribunal found that the amounts were offered to tax in subsequent assessment years and taxed on profits thereon, making the AO's estimate result in double taxation; accordingly the addition treating such stock/advances as turnover was deleted. Reliance on precedents supporting deletion where income is taxed in later years was noted. Resultantly, all grounds of appeal raising this treatment were allowed and the impugned additions were set aside.
Dispute concerns revenue recognition where the assessing officer treated finished goods/advances as sales despite the assessee following the project completion method. The tribunal found that the amounts were offered to tax in subsequent assessment years and taxed on profits thereon, making the AO's estimate result in double taxation; accordingly the addition treating such stock/advances as turnover was deleted. Reliance on precedents supporting deletion where income is taxed in later years was noted. Resultantly, all grounds of appeal raising this treatment were allowed and the impugned additions were set aside.
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