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...
Unabsorbed depreciation carried forward under Section 32(2) retains the character of current-year loss and may be set off against business income or other income, except capital gains; on that basis, the assessee was entitled to set off the depreciation against the addition made for unaccounted stock. The revenue's reliance on Section 79A failed because it was inserted later and applied only from 01.04.2022, and Section 115BBE(2) was also inapplicable because the assessment was not framed under that provision. The substantial questions of law were answered in favour of the assessee.
Unabsorbed depreciation carried forward under Section 32(2) retains the character of current-year loss and may be set off against business income or other income, except capital gains; on that basis, the assessee was entitled to set off the depreciation against the addition made for unaccounted stock. The revenue's reliance on Section 79A failed because it was inserted later and applied only from 01.04.2022, and Section 115BBE(2) was also inapplicable because the assessment was not framed under that provision. The substantial questions of law were answered in favour of the assessee.
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