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...
Telescoping was applied to undisclosed on-money receipts against cash deposits made during demonetisation, but only 50% relief was granted because no corresponding physical cash was found and the assessee could not fully explain that aspect. The surviving addition was held not chargeable under section 115BBE for the year in question, and had to be taxed under the normal provisions. Receipts described as advances from customers and a loan receipt were treated as business turnover already covered by the telescoping of on-money and were deleted as separate section 68 additions. An addition relating to a creditor was also deleted because the assessee had discharged the initial onus with documents and the creditor had been examined without adverse findings.
Telescoping was applied to undisclosed on-money receipts against cash deposits made during demonetisation, but only 50% relief was granted because no corresponding physical cash was found and the assessee could not fully explain that aspect. The surviving addition was held not chargeable under section 115BBE for the year in question, and had to be taxed under the normal provisions. Receipts described as advances from customers and a loan receipt were treated as business turnover already covered by the telescoping of on-money and were deleted as separate section 68 additions. An addition relating to a creditor was also deleted because the assessee had discharged the initial onus with documents and the creditor had been examined without adverse findings.
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