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...
The High Court noted that the Supreme Court, in identical reassessment matters, had set aside earlier quashing orders and remitted the cases for fresh consideration while keeping all merits issues open. In light of that binding development, the Court declined to examine the controversy on merits, set aside the Single Judge's order, and remitted the matter for reconsideration with all contentions preserved. The Court also granted the assessee liberty to challenge newly inserted section 147A and any connected or consequential provisions, consistent with the Supreme Court's permission in similar matters, and allowed the Revenue to file further affidavit or submissions.
The High Court noted that the Supreme Court, in identical reassessment matters, had set aside earlier quashing orders and remitted the cases for fresh consideration while keeping all merits issues open. In light of that binding development, the Court declined to examine the controversy on merits, set aside the Single Judge's order, and remitted the matter for reconsideration with all contentions preserved. The Court also granted the assessee liberty to challenge newly inserted section 147A and any connected or consequential provisions, consistent with the Supreme Court's permission in similar matters, and allowed the Revenue to file further affidavit or submissions.
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