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...
Imported technical know-how from a foreign entity was not taxable as intellectual property service on reverse charge because the alleged intellectual property was not shown to be recognised under Indian law; the demand was therefore unsustainable and dropped. A composite engineering development arrangement was not taxable as consulting engineering service because the agreement involved joint development, design, detailing, prototype work and production support rather than advice, consultancy or technical assistance simpliciter; the demand was set aside. As both demands failed, issues of limitation, revenue neutrality, interest and penalty did not survive.
Imported technical know-how from a foreign entity was not taxable as intellectual property service on reverse charge because the alleged intellectual property was not shown to be recognised under Indian law; the demand was therefore unsustainable and dropped. A composite engineering development arrangement was not taxable as consulting engineering service because the agreement involved joint development, design, detailing, prototype work and production support rather than advice, consultancy or technical assistance simpliciter; the demand was set aside. As both demands failed, issues of limitation, revenue neutrality, interest and penalty did not survive.
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