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...
Tribunal held that estimating undisclosed income by applying a percentage to sales turnover was unsustainable where books showed purchases and sales, payments passed through banking channels, no cash introductions were proved, and AO did not justify the rate; consequently additions based on turnover estimation were deleted. The tribunal upheld allowability of depreciation and indirect/finance expenses because expenditures were recorded, payments evidenced, and no material showed expenses were fictitious. Additions treating intra group unsecured loans as unexplained cash credits were deleted where creditor identity and creditworthiness, ledger entries, repayments, prior advances and bank records supported the transactions.
Tribunal held that estimating undisclosed income by applying a percentage to sales turnover was unsustainable where books showed purchases and sales, payments passed through banking channels, no cash introductions were proved, and AO did not justify the rate; consequently additions based on turnover estimation were deleted. The tribunal upheld allowability of depreciation and indirect/finance expenses because expenditures were recorded, payments evidenced, and no material showed expenses were fictitious. Additions treating intra group unsecured loans as unexplained cash credits were deleted where creditor identity and creditworthiness, ledger entries, repayments, prior advances and bank records supported the transactions.
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