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...
Declaration under the Income Declaration Scheme was held void for failure to pay tax, surcharge and penalty within the statutory time, rendering the declaration deemed never made and making the undeclared amount chargeable in the previous year (FY 2016-17) under the deeming provision; because the assessee failed to satisfactorily explain the source, the AO's addition as unexplained investment was upheld. The amended higher tax rate was held non-retrospective, so tax on the addition must be computed at the earlier 30% rate rather than the later 60% rate, resulting in a partly allowed outcome.
Declaration under the Income Declaration Scheme was held void for failure to pay tax, surcharge and penalty within the statutory time, rendering the declaration deemed never made and making the undeclared amount chargeable in the previous year (FY 2016-17) under the deeming provision; because the assessee failed to satisfactorily explain the source, the AO's addition as unexplained investment was upheld. The amended higher tax rate was held non-retrospective, so tax on the addition must be computed at the earlier 30% rate rather than the later 60% rate, resulting in a partly allowed outcome.
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