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 reopening for AY 2016-17 failed because the Revenue did not allege escapement represented in the form of an asset, so jurisdiction under the search-based block was invalid; the assessment was quashed. It also held that the enhanced tax rate under section 115BBE applied only from 01.04.2017, so it could not be levied for AY 2017-18. Additions for alleged over-invoicing and bogus purchases were deleted because the books and quantitative records were not rejected and the claimed purchases matched the amounts actually billed and paid. CSR expenditure remained disallowable as business expense, but the alternative deduction claim was remanded for fresh examination.
ITAT held that reopening for AY 2016-17 failed because the Revenue did not allege escapement represented in the form of an asset, so jurisdiction under the search-based block was invalid; the assessment was quashed. It also held that the enhanced tax rate under section 115BBE applied only from 01.04.2017, so it could not be levied for AY 2017-18. Additions for alleged over-invoicing and bogus purchases were deleted because the books and quantitative records were not rejected and the claimed purchases matched the amounts actually billed and paid. CSR expenditure remained disallowable as business expense, but the alternative deduction claim was remanded for fresh examination.
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