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 primary issue was whether principles of natural justice were violated by improper service of the show-cause notice and failure to physically serve notice of personal hearing. The court found the record establishes no physical service of the SCN or effective personal-hearing notice, meaning the petitioner was deprived of an opportunity to respond; the court relied on relevant precedents holding similar non-service vitiates proceedings. Consequence: the impugned orders were held to be in violation of natural justice and the petition was partly allowed, setting aside the affected orders. - HC
The primary issue was whether principles of natural justice were violated by improper service of the show-cause notice and failure to physically serve notice of personal hearing. The court found the record establishes no physical service of the SCN or effective personal-hearing notice, meaning the petitioner was deprived of an opportunity to respond; the court relied on relevant precedents holding similar non-service vitiates proceedings. Consequence: the impugned orders were held to be in violation of natural justice and the petition was partly allowed, setting aside the affected orders. - HC
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