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...
Proceedings under Section 148A cannot be initiated against a deceased assessee; where the assessee has died, the Department must invoke the statutory mechanism under Section 159 against the legal representatives. As that route was not followed here, the notices were unsustainable and were quashed, while liberty was preserved for the Department to proceed in accordance with law against the legal representatives.
Proceedings under Section 148A cannot be initiated against a deceased assessee; where the assessee has died, the Department must invoke the statutory mechanism under Section 159 against the legal representatives. As that route was not followed here, the notices were unsustainable and were quashed, while liberty was preserved for the Department to proceed in accordance with law against the legal representatives.
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