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...
Disallowance of salary expenses was reversed where the taxpayer produced employee-wise breakup, designations, locations and salary details and no evidence of sham payments or diversion of funds was shown; AO's salary disallowance deleted. Non-deduction of tax at source on cross-border/reimbursement payments was held not to be a standalone ground for disallowance where payments were characterised as reimbursements, supported by particulars and did not prima facie attract TDS; 40(a)(i) addition deleted. Addition for alleged undisclosed receipts was deleted after the assessee furnished corresponding receipt particulars and TDS credit documentation, and Revenue produced no contrary proof. Appeal dismissed.
Disallowance of salary expenses was reversed where the taxpayer produced employee-wise breakup, designations, locations and salary details and no evidence of sham payments or diversion of funds was shown; AO's salary disallowance deleted. Non-deduction of tax at source on cross-border/reimbursement payments was held not to be a standalone ground for disallowance where payments were characterised as reimbursements, supported by particulars and did not prima facie attract TDS; 40(a)(i) addition deleted. Addition for alleged undisclosed receipts was deleted after the assessee furnished corresponding receipt particulars and TDS credit documentation, and Revenue produced no contrary proof. Appeal dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
