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...
Books of account of a project office cannot be rejected merely because no revenue was shown in the year and only expenditure was claimed; absent cogent material, such rejection is unsustainable, and the appellate deletion of its consequences was upheld. Additions made by treating a foreign exchange item as fees for technical services and by treating head office remittances as undisclosed income also failed because they were unsupported by substance or material evidence. The ITAT agreed with the Commissioner (Appeals) that the assessee's project-office receipts and remittances did not justify the impugned additions, and it dismissed the Revenue's appeal.
Books of account of a project office cannot be rejected merely because no revenue was shown in the year and only expenditure was claimed; absent cogent material, such rejection is unsustainable, and the appellate deletion of its consequences was upheld. Additions made by treating a foreign exchange item as fees for technical services and by treating head office remittances as undisclosed income also failed because they were unsupported by substance or material evidence. The ITAT agreed with the Commissioner (Appeals) that the assessee's project-office receipts and remittances did not justify the impugned additions, and it dismissed the Revenue's appeal.
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