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...
Where the Assessing Officer recorded inconsistencies between the return, balance sheet and construction agreement and expressly considered then rejected the assessee's books of account, referral to the District Valuation Officer for valuation was held permissible; the court applied the principle that a DVO report may be relied on only after rejection of books and found that factual record satisfied that rule. The HC endorsed the Tribunal and CIT(A) directions, approved adoption of State PWD rates for valuation, treated the omitted investment as escaped income and dismissed the tax appeal.
Where the Assessing Officer recorded inconsistencies between the return, balance sheet and construction agreement and expressly considered then rejected the assessee's books of account, referral to the District Valuation Officer for valuation was held permissible; the court applied the principle that a DVO report may be relied on only after rejection of books and found that factual record satisfied that rule. The HC endorsed the Tribunal and CIT(A) directions, approved adoption of State PWD rates for valuation, treated the omitted investment as escaped income and dismissed the tax appeal.
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