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 for alleged bogus accommodation entries was limited by the tribunal to a specified percentage following precedent, so the excess addition was restricted. Depreciation denial was overturned because the assessing officer doubted asset valuation without rejecting books of account or providing valuation basis; surmatory estimates by survey personnel were held insufficient, restoring depreciation. Denial of deduction as a result of delayed return filing was treated as procedural rather than fundamental when the assessee gave reasonable cause and filed Form 10CCB on time, permitting the claim.
Addition for alleged bogus accommodation entries was limited by the tribunal to a specified percentage following precedent, so the excess addition was restricted. Depreciation denial was overturned because the assessing officer doubted asset valuation without rejecting books of account or providing valuation basis; surmatory estimates by survey personnel were held insufficient, restoring depreciation. Denial of deduction as a result of delayed return filing was treated as procedural rather than fundamental when the assessee gave reasonable cause and filed Form 10CCB on time, permitting the claim.
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