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...
Telescoping was accepted on the basis of surplus funds from earlier assessment years, so the sustained additions for shortage of funds in AY 2000-01 and for undisclosed income and vehicle investment in AY 2002-03 did not survive. For AY 2002-03, the capital gains addition was confined to the assessee's own computation because the higher figure in the appellate order was treated as an inadvertent error. The deduction claim under section 54 was rejected for want of substantiation.
Telescoping was accepted on the basis of surplus funds from earlier assessment years, so the sustained additions for shortage of funds in AY 2000-01 and for undisclosed income and vehicle investment in AY 2002-03 did not survive. For AY 2002-03, the capital gains addition was confined to the assessee's own computation because the higher figure in the appellate order was treated as an inadvertent error. The deduction claim under section 54 was rejected for want of substantiation.
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