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 court held that where the subject matter relates to different financial years, a composite intimation and single show-cause notice are impermissible: separate intimations and, after considering statutory replies, separate DRC-01 show-cause proceedings are required - consequence: the impugned intimation and show-cause notice are quashed and set aside. The court permitted respondents liberty to reinitiate proceedings lawfully and to take appropriate action on or before 15.1.2026, and directed that any adjudication thereafter be completed within a reasonable time but not later than 31.3.2026. - HC
The court held that where the subject matter relates to different financial years, a composite intimation and single show-cause notice are impermissible: separate intimations and, after considering statutory replies, separate DRC-01 show-cause proceedings are required - consequence: the impugned intimation and show-cause notice are quashed and set aside. The court permitted respondents liberty to reinitiate proceedings lawfully and to take appropriate action on or before 15.1.2026, and directed that any adjudication thereafter be completed within a reasonable time but not later than 31.3.2026. - HC
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