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 challenge concerned validity of detention show cause proceedings where the notice and FORM MOV-7/MOV-9 were alleged to have been uploaded to the portal belatedly and no personal hearing was afforded. The failure to comply with mandated portal uploading timelines was held to cast doubt on the purportedly dated order, resulting in its invalidation. The denial of opportunity of hearing rendered the proceedings ex parte and further supported quashing. For these reasons the impugned show cause notice and consequential administrative action were quashed and set aside without remand.
The challenge concerned validity of detention show cause proceedings where the notice and FORM MOV-7/MOV-9 were alleged to have been uploaded to the portal belatedly and no personal hearing was afforded. The failure to comply with mandated portal uploading timelines was held to cast doubt on the purportedly dated order, resulting in its invalidation. The denial of opportunity of hearing rendered the proceedings ex parte and further supported quashing. For these reasons the impugned show cause notice and consequential administrative action were quashed and set aside without remand.
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