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 concerned additions to income under section 68 and section 56(2)(viib) alleging unexplained large share capital and excessive premium. Tribunal found that notices to lenders were duly issued and acknowledged and that lenders filed confirmations, so the file contained materials establishing the genuineness, identity and creditworthiness of creditors; this factual appreciation led to dismissal of the revenue's appeal. Non-appearance of directors under summons was noted but did not negate the documentary evidence confirming transactions.
Dispute concerned additions to income under section 68 and section 56(2)(viib) alleging unexplained large share capital and excessive premium. Tribunal found that notices to lenders were duly issued and acknowledged and that lenders filed confirmations, so the file contained materials establishing the genuineness, identity and creditworthiness of creditors; this factual appreciation led to dismissal of the revenue's appeal. Non-appearance of directors under summons was noted but did not negate the documentary evidence confirming transactions.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4817 
Join Channel 
