Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
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The High Court considered a Revision u/s 264 where the CIT rejected the application due to delay, stating u/s 143(1) intimation was not revisable. The court declined to condone the delay, noting the tax department's inability to reassess due to limitation provisions. The appellant had initially declared profits as capital gains for certain years, benefiting from lower tax rates. The revenue's change in treating the profits as business income led to the revision petitions. The court found the delay unjustifiable, as the appellant waited until after the Appellate Authority's decision to file the revision petitions. Condoning the delay would unfairly advantage the appellant over the revenue. The Writ Appeal was dismissed in line with the Single Judge's decision.
The High Court considered a Revision u/s 264 where the CIT rejected the application due to delay, stating u/s 143(1) intimation was not revisable. The court declined to condone the delay, noting the tax department's inability to reassess due to limitation provisions. The appellant had initially declared profits as capital gains for certain years, benefiting from lower tax rates. The revenue's change in treating the profits as business income led to the revision petitions. The court found the delay unjustifiable, as the appellant waited until after the Appellate Authority's decision to file the revision petitions. Condoning the delay would unfairly advantage the appellant over the revenue. The Writ Appeal was dismissed in line with the Single Judge's decision.
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