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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High Court found an ex parte assessment order issued after the petitioner failed to file a reply to a show cause notice was procedurally vitiated for breach of natural justice, quashed the impugned order and remitted the matter to the first respondent for fresh adjudication on merits. The petitioner must deposit 50% of the disputed tax within 30 days and file a reply to the Form DRC-01 show cause notice with supporting documents; overlapping earlier demand may be explained and pre-deposited. On compliance, the respondent shall pass a final order expeditiously and the bank attachment will stand vacated.
High Court found an ex parte assessment order issued after the petitioner failed to file a reply to a show cause notice was procedurally vitiated for breach of natural justice, quashed the impugned order and remitted the matter to the first respondent for fresh adjudication on merits. The petitioner must deposit 50% of the disputed tax within 30 days and file a reply to the Form DRC-01 show cause notice with supporting documents; overlapping earlier demand may be explained and pre-deposited. On compliance, the respondent shall pass a final order expeditiously and the bank attachment will stand vacated.
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