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...
The note addresses tax consequences of undisputed TDS non-deduction and unexplained loan credits: the applicable disallowance for failure to deduct tax at source is confined to thirty percent of the admitted shortfall, limiting the assessor's large-scale disallowance to that proportion; and an addition treated as unexplained cash credit based on increased unsecured loans was deleted where the assessee furnished primary documents (confirmations, ITRs, bank statements), shifting the onus to the revenue to rebut those records and no adverse material was produced.
The note addresses tax consequences of undisputed TDS non-deduction and unexplained loan credits: the applicable disallowance for failure to deduct tax at source is confined to thirty percent of the admitted shortfall, limiting the assessor's large-scale disallowance to that proportion; and an addition treated as unexplained cash credit based on increased unsecured loans was deleted where the assessee furnished primary documents (confirmations, ITRs, bank statements), shifting the onus to the revenue to rebut those records and no adverse material was produced.
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