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...
Reopening after search was held time barred for the 2012-13 assessment as the notice under section 148 fell outside the ten year limitation and the reassessment was quashed. The note states that only the profit element of undisclosed 'on money' is taxable, and a uniform estimation rate of 10% was applied on the facts. Unaccounted profit is taxable in the year of execution of the sale deed (transfer), with ICDS III inapplicable. Issues of alleged negative cash balances were remitted to the AO for verification. Telescoping deletions under unexplained money were upheld where an assessed profit exceeded other applications, and a seized ledger corroborated a short term capital gain addition.
Reopening after search was held time barred for the 2012-13 assessment as the notice under section 148 fell outside the ten year limitation and the reassessment was quashed. The note states that only the profit element of undisclosed 'on money' is taxable, and a uniform estimation rate of 10% was applied on the facts. Unaccounted profit is taxable in the year of execution of the sale deed (transfer), with ICDS III inapplicable. Issues of alleged negative cash balances were remitted to the AO for verification. Telescoping deletions under unexplained money were upheld where an assessed profit exceeded other applications, and a seized ledger corroborated a short term capital gain addition.
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