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...
Declared business receipts under presumptive taxation could not be rejected as bogus merely because sales were concentrated in one month, where the assessee was regularly engaged in scrap trading and had returned income under section 44AD. The Tribunal noted that in such business there was no fixed pattern of purchases and sales, and books of account were not required in the manner assumed by the Assessing Officer. The addition treating the declared sales as unexplained cash credit was based only on suspicion and lacked a sustainable factual basis, so it was deleted.
Declared business receipts under presumptive taxation could not be rejected as bogus merely because sales were concentrated in one month, where the assessee was regularly engaged in scrap trading and had returned income under section 44AD. The Tribunal noted that in such business there was no fixed pattern of purchases and sales, and books of account were not required in the manner assumed by the Assessing Officer. The addition treating the declared sales as unexplained cash credit was based only on suspicion and lacked a sustainable factual basis, so it was deleted.
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