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...
Where reopening is founded on material seized in a third-party search, section 153C operates as the special procedure for assessment of that other person and overrides general reassessment under section 147; the reassessment was therefore void ab initio and the annulment was upheld. On merits, additions for alleged cash loans and interest based only on a retracted survey statement could not stand because no independent corroborative evidence was produced and the seized broker documents did not implicate the assessee. The Tribunal accordingly dismissed the Revenue's challenge and sustained the finding that the additions were unsustainable.
Where reopening is founded on material seized in a third-party search, section 153C operates as the special procedure for assessment of that other person and overrides general reassessment under section 147; the reassessment was therefore void ab initio and the annulment was upheld. On merits, additions for alleged cash loans and interest based only on a retracted survey statement could not stand because no independent corroborative evidence was produced and the seized broker documents did not implicate the assessee. The Tribunal accordingly dismissed the Revenue's challenge and sustained the finding that the additions were unsustainable.
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