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...
In limited scrutiny, the AO's jurisdiction is confined to the specific issues for which the case was selected. The Tribunal found that the scrutiny parameter referred only to transfer of property by the assessee and did not extend to acquisition or purchase of property. As there was no material showing a valid conversion of the assessment into complete scrutiny with approval of the competent authority, the addition for alleged unexplained investment in purchase of immovable property was beyond jurisdiction and contrary to the CBDT circular governing scrutiny assessments. The addition was therefore deleted and the appellate order set aside.
In limited scrutiny, the AO's jurisdiction is confined to the specific issues for which the case was selected. The Tribunal found that the scrutiny parameter referred only to transfer of property by the assessee and did not extend to acquisition or purchase of property. As there was no material showing a valid conversion of the assessment into complete scrutiny with approval of the competent authority, the addition for alleged unexplained investment in purchase of immovable property was beyond jurisdiction and contrary to the CBDT circular governing scrutiny assessments. The addition was therefore deleted and the appellate order set aside.
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