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...
ITAT determined that excess stock discovered on survey comprised trading/manufacturing goods and constituted income from business; therefore it should be assessed under the head 'income from business' rather than as deemed income attractable to special taxation provisions. The tribunal found admissions during survey and absence of evidence of non-business sources supported business classification, directed the AO to permit set off of current year and carried forward business losses and depreciation against the assessed business income, and directed that special rate taxation provisions not be applied.
ITAT determined that excess stock discovered on survey comprised trading/manufacturing goods and constituted income from business; therefore it should be assessed under the head 'income from business' rather than as deemed income attractable to special taxation provisions. The tribunal found admissions during survey and absence of evidence of non-business sources supported business classification, directed the AO to permit set off of current year and carried forward business losses and depreciation against the assessed business income, and directed that special rate taxation provisions not be applied.
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