Effective service requirement: officers must explore alternative service modes beyond the GST portal and afford personal hearing; non-compliance voids...
Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
An addition to taxable income based on an erroneous entry in the original tax-audit report was unsustainable where the assessee produced evidence of a substantially lower correct figure and the auditor subsequently revised and uploaded a corrected audit report; the appellate finding stressed that the evidentiary weight of an audit report is not absolute and must yield where a demonstrable clerical/figural error has been rectified, and that the first appellate authority's reliance on the uncorrected report was unreasonable. Operative effect: the addition set aside and the Assessing Officer directed to delete the disallowance for the relevant assessment year.
An addition to taxable income based on an erroneous entry in the original tax-audit report was unsustainable where the assessee produced evidence of a substantially lower correct figure and the auditor subsequently revised and uploaded a corrected audit report; the appellate finding stressed that the evidentiary weight of an audit report is not absolute and must yield where a demonstrable clerical/figural error has been rectified, and that the first appellate authority's reliance on the uncorrected report was unreasonable. Operative effect: the addition set aside and the Assessing Officer directed to delete the disallowance for the relevant assessment year.
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