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...
Addition claimed as cessation of liability for alleged non existent sundry creditors was examined where the AO had accepted increased purchases, sales and consequent creditor balances and prior years' assessments similarly accepted such creditors. The tribunal found sample based non verification of 29.24% of creditors insufficient to displace accepted trading results, and relied on higher court precedents to hold that no addition under cessation of liability principles was warranted. The AO's addition was deleted and the tax effect reversed in favour of the assessee.
Addition claimed as cessation of liability for alleged non existent sundry creditors was examined where the AO had accepted increased purchases, sales and consequent creditor balances and prior years' assessments similarly accepted such creditors. The tribunal found sample based non verification of 29.24% of creditors insufficient to displace accepted trading results, and relied on higher court precedents to hold that no addition under cessation of liability principles was warranted. The AO's addition was deleted and the tax effect reversed in favour of the assessee.
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