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...
Denial of TDS credit arose from non-production of relevant documents; tribunal found tax was lawfully deposited and non-production resulted from a bona fide belief, not malafide, and therefore admission of additional evidence was warranted, with the consequence that the evidence should be admitted and considered. The tribunal directed restoration to the assessing officer to permit the assessee to file additional evidence within a prescribed period and ordered the AO, after verification, to allow the TDS credit as per law; grounds allowed for statistical purposes.
Denial of TDS credit arose from non-production of relevant documents; tribunal found tax was lawfully deposited and non-production resulted from a bona fide belief, not malafide, and therefore admission of additional evidence was warranted, with the consequence that the evidence should be admitted and considered. The tribunal directed restoration to the assessing officer to permit the assessee to file additional evidence within a prescribed period and ordered the AO, after verification, to allow the TDS credit as per law; grounds allowed for statistical purposes.
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