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...
Seized loose sheets, Rojmel, MITI and related digital records were held to have evidentiary value where the Assessing Officer had correlated them with each other and the assessees showed no specific defect or alternative explanation; retraction affidavits by employees did not neutralise the seized material. The Tribunal also rejected the claim that all entries were mere facilitation passes, holding that some reflected the assessees' own unaccounted sales and cash receipts. Profit, however, had to be estimated on a rational basis rather than guesswork: 4% was applied to undisclosed own transactions and cash sales, and 1.5% to facilitation-based transactions in the LLP matter, while 4% was applied to unaccounted cash sales of the trading concerns.
Seized loose sheets, Rojmel, MITI and related digital records were held to have evidentiary value where the Assessing Officer had correlated them with each other and the assessees showed no specific defect or alternative explanation; retraction affidavits by employees did not neutralise the seized material. The Tribunal also rejected the claim that all entries were mere facilitation passes, holding that some reflected the assessees' own unaccounted sales and cash receipts. Profit, however, had to be estimated on a rational basis rather than guesswork: 4% was applied to undisclosed own transactions and cash sales, and 1.5% to facilitation-based transactions in the LLP matter, while 4% was applied to unaccounted cash sales of the trading concerns.
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