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...
Allowability of business expenditure: the tribunal applied its prior assessment-year finding on identical facts that power and fuel costs from a captive power plant were genuine business expenses utilised for manufacturing, and therefore upheld deletion of their disallowance against the assessee. Disallowance under Rule 8D: the tribunal reiterated that disallowance calculated under the rule cannot exceed the amount of exempt income for the year, rejected reliance on an administrative circular to enlarge the disallowance, and sustained the CIT(A)'s restriction to exempt income. Appeals allowed for the assessee; revenue appeals dismissed.
Allowability of business expenditure: the tribunal applied its prior assessment-year finding on identical facts that power and fuel costs from a captive power plant were genuine business expenses utilised for manufacturing, and therefore upheld deletion of their disallowance against the assessee. Disallowance under Rule 8D: the tribunal reiterated that disallowance calculated under the rule cannot exceed the amount of exempt income for the year, rejected reliance on an administrative circular to enlarge the disallowance, and sustained the CIT(A)'s restriction to exempt income. Appeals allowed for the assessee; revenue appeals dismissed.
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