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...
ITAT held that cash deposits supported by recorded cash sales could not be treated as unexplained cash credit where the assessee produced purchase and sales registers, no specific discrepancy was found in sales, purchases or cash book, and the books were not rejected; absence of a stock register alone was insufficient, so the section 68 addition on that account was deleted. For the claimed capital introduction based on an alleged gift, the appellate relief was unsustainable because the new material was not properly tested through due process, including verification of the donor's identity, genuineness and creditworthiness; that issue was set aside and remanded to the AO for de novo adjudication.
ITAT held that cash deposits supported by recorded cash sales could not be treated as unexplained cash credit where the assessee produced purchase and sales registers, no specific discrepancy was found in sales, purchases or cash book, and the books were not rejected; absence of a stock register alone was insufficient, so the section 68 addition on that account was deleted. For the claimed capital introduction based on an alleged gift, the appellate relief was unsustainable because the new material was not properly tested through due process, including verification of the donor's identity, genuineness and creditworthiness; that issue was set aside and remanded to the AO for de novo adjudication.
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