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...
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The Tribunal upheld taxation under the concessional regime of section 115BAA and held that section 115JB could not be applied for the year in dispute. It accepted the first appellate authority's view that the assessee's option under section 115BAA was valid, and rejected the Revenue's objection based on the timing of filing Form 10-IC. The Tribunal also noted that the assessee had been processed under section 115BAA for three earlier years, and applied the principle of consistency to support the same tax treatment for the year under appeal. The Revenue's challenge was dismissed and the appellate relief was sustained.
The Tribunal upheld taxation under the concessional regime of section 115BAA and held that section 115JB could not be applied for the year in dispute. It accepted the first appellate authority's view that the assessee's option under section 115BAA was valid, and rejected the Revenue's objection based on the timing of filing Form 10-IC. The Tribunal also noted that the assessee had been processed under section 115BAA for three earlier years, and applied the principle of consistency to support the same tax treatment for the year under appeal. The Revenue's challenge was dismissed and the appellate relief was sustained.
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