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 dominant issue was whether the circuit bench had territorial jurisdiction to entertain an appeal and cross-objection arising from an assessment order passed by an assessing officer at another station. On a reference due to a difference of opinion between members, the third member held that the circuit bench lacked jurisdiction over the appeal; consequently, the appeal was not maintainable and was dismissed. Parties were left at liberty to pursue appropriate remedies before the competent forum, and the revenue was similarly permitted to approach the appropriate forum if so advised. - ITAT
The dominant issue was whether the circuit bench had territorial jurisdiction to entertain an appeal and cross-objection arising from an assessment order passed by an assessing officer at another station. On a reference due to a difference of opinion between members, the third member held that the circuit bench lacked jurisdiction over the appeal; consequently, the appeal was not maintainable and was dismissed. Parties were left at liberty to pursue appropriate remedies before the competent forum, and the revenue was similarly permitted to approach the appropriate forum if so advised. - ITAT
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