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...
Additions under section 69A for alleged clandestine sales and unexplained investment failed because the underlying charge of clandestine removal was not sustained in excise proceedings. The ITAT noted that, for another year on the same factual basis, the appellate authority had already deleted similar additions after the CESTAT found the excise allegation unsustainable. Once the allegation of unaccounted sales did not survive, the additions based solely on that premise had no independent evidentiary footing and could not be maintained. The appeal was therefore allowed and the additions deleted.
Additions under section 69A for alleged clandestine sales and unexplained investment failed because the underlying charge of clandestine removal was not sustained in excise proceedings. The ITAT noted that, for another year on the same factual basis, the appellate authority had already deleted similar additions after the CESTAT found the excise allegation unsustainable. Once the allegation of unaccounted sales did not survive, the additions based solely on that premise had no independent evidentiary footing and could not be maintained. The appeal was therefore allowed and the additions deleted.
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