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...
Reopening an income-tax assessment on the same factual material already forming the subject of consideration before the appellate authority was impermissible where additions originated from digital data seized during a search and used under the separate statutory provision dealing with search-derived material. The reasoning rested on the bar against initiating reassessment proceedings based on identical seized material that was under appellate scrutiny, and consequently the reopening notice was quashed, preventing further reassessment on that same material.
Reopening an income-tax assessment on the same factual material already forming the subject of consideration before the appellate authority was impermissible where additions originated from digital data seized during a search and used under the separate statutory provision dealing with search-derived material. The reasoning rested on the bar against initiating reassessment proceedings based on identical seized material that was under appellate scrutiny, and consequently the reopening notice was quashed, preventing further reassessment on that same material.
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