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...
Treatment of unaccounted investment in immovable property turned on whether a bank valuation report constituted incriminating material in a search assessment; appellate authority found no incriminating material and sustained deletion of additions disallowing reliance on that valuation. Separate STCG adjustment based on AO's adoption of the DVO estimate at 120% (20% escalation) was held to be a baseless simplicitor estimation; the appellate authority rejected the enhanced valuation and deleted the STCG addition accordingly.
Treatment of unaccounted investment in immovable property turned on whether a bank valuation report constituted incriminating material in a search assessment; appellate authority found no incriminating material and sustained deletion of additions disallowing reliance on that valuation. Separate STCG adjustment based on AO's adoption of the DVO estimate at 120% (20% escalation) was held to be a baseless simplicitor estimation; the appellate authority rejected the enhanced valuation and deleted the STCG addition accordingly.
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