Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
Reopening of assessment was challenged on the ground that the assessing officer had accepted the assessee's explanation regarding the source of investment in property. The tribunal relied on precedent to conclude that once the AO accepted the explanation recorded in reasons, the AO lacked basis to make an independent addition in respect of that subject-matter. Consequently, the addition made in the assessment was deleted and the assessment adjustment was set aside in favour of the assessee.
Reopening of assessment was challenged on the ground that the assessing officer had accepted the assessee's explanation regarding the source of investment in property. The tribunal relied on precedent to conclude that once the AO accepted the explanation recorded in reasons, the AO lacked basis to make an independent addition in respect of that subject-matter. Consequently, the addition made in the assessment was deleted and the assessment adjustment was set aside in favour of the assessee.
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