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...
Rejection of books of account under assessment law led to estimation of income because the assessee could not satisfactorily explain cash deposits in a bank; the assessing officer concluded sales were inflated to understate firm profit, and cash receipts were not shown as explainable sales proceeds. The tribunal noted the business is wholesale beer (lower margins than liquor) and found the disclosed net profit (0.15%) inadequate; it increased the assumed net profit to 0.50% of turnover to address deficiencies and directed the assessing officer to recompute total income accordingly. Appeal partly allowed.
Rejection of books of account under assessment law led to estimation of income because the assessee could not satisfactorily explain cash deposits in a bank; the assessing officer concluded sales were inflated to understate firm profit, and cash receipts were not shown as explainable sales proceeds. The tribunal noted the business is wholesale beer (lower margins than liquor) and found the disclosed net profit (0.15%) inadequate; it increased the assumed net profit to 0.50% of turnover to address deficiencies and directed the assessing officer to recompute total income accordingly. Appeal partly allowed.
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