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...
Assessee's liability to collect and deposit TCS on scrap was examined on the basis of filed Form 27EQ returns, quarterly acknowledgements and a reconciliation matching scrap sales in TCS returns with audited accounts; the tribunal accepted a detailed quarterly summary showing TCS collected and adjustments (including roll-scrap treated as asset sale and duties/taxes) and held that these documentary reconciliations established collection and deposit of TCS. Operative effect: the assessment officer's imposition of additional TCS liability was found unsustainable and the order levying extra TCS was set aside.
Assessee's liability to collect and deposit TCS on scrap was examined on the basis of filed Form 27EQ returns, quarterly acknowledgements and a reconciliation matching scrap sales in TCS returns with audited accounts; the tribunal accepted a detailed quarterly summary showing TCS collected and adjustments (including roll-scrap treated as asset sale and duties/taxes) and held that these documentary reconciliations established collection and deposit of TCS. Operative effect: the assessment officer's imposition of additional TCS liability was found unsustainable and the order levying extra TCS was set aside.
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