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Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Condonation of delay: The HC allowed the writ petition and set aside the impugned orders, including the Senior Joint Commissioner's order dated 06.07.2018, subject to the petitioner paying 15% of the disputed tax u/s 84(1) within 30 days. Considering the high-pitched ex-parte assessment where the government could not recover any tax till date, the HC granted one opportunity to the petitioner to pursue their appeal before the Senior Joint Commissioner after complying with the pre-deposit condition.
Condonation of delay: The HC allowed the writ petition and set aside the impugned orders, including the Senior Joint Commissioner's order dated 06.07.2018, subject to the petitioner paying 15% of the disputed tax u/s 84(1) within 30 days. Considering the high-pitched ex-parte assessment where the government could not recover any tax till date, the HC granted one opportunity to the petitioner to pursue their appeal before the Senior Joint Commissioner after complying with the pre-deposit condition.
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TaxTMI 
TaxTMI 
