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...
ITAT upheld rejection of the books of account because the assessee's cash sales, cash on hand and pre-demonetisation cash deposits showed an abnormal rise, while the supporting invoices were incomplete, generic and not backed by genuine evidence, so the accounts did not reflect a true and correct picture of business. On unexplained demonetisation-period cash deposits, the Tribunal accepted credit for the opening cash balance and bank withdrawals where no discrepancy was found, and sustained addition only for the balance amount remaining unexplained. It further held that the sustained addition under section 68 was taxable at the special rate under section 115BBE for AY 2017-18.
ITAT upheld rejection of the books of account because the assessee's cash sales, cash on hand and pre-demonetisation cash deposits showed an abnormal rise, while the supporting invoices were incomplete, generic and not backed by genuine evidence, so the accounts did not reflect a true and correct picture of business. On unexplained demonetisation-period cash deposits, the Tribunal accepted credit for the opening cash balance and bank withdrawals where no discrepancy was found, and sustained addition only for the balance amount remaining unexplained. It further held that the sustained addition under section 68 was taxable at the special rate under section 115BBE for AY 2017-18.
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