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...
Whether proceedings under Section 153C were validly initiated: Court held the foundational statutory prerequisite-creation of an asset under the scheme and the fourth proviso to Section 153A-appears absent because the ledger entries relate to expenditure and TDS was deducted, undermining the jurisdictional basis for a Section 153C notice; outcome: petitioner has a plausible ground to oppose the proceedings. Direction to assessing officer to decide petitioner's objections and pass a reasoned order within the specified short period, with communication to petitioner. - HC
Whether proceedings under Section 153C were validly initiated: Court held the foundational statutory prerequisite-creation of an asset under the scheme and the fourth proviso to Section 153A-appears absent because the ledger entries relate to expenditure and TDS was deducted, undermining the jurisdictional basis for a Section 153C notice; outcome: petitioner has a plausible ground to oppose the proceedings. Direction to assessing officer to decide petitioner's objections and pass a reasoned order within the specified short period, with communication to petitioner. - HC
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