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...
Cancellation of registration was set aside for failure to consider the taxpayer's uploaded reply to the show-cause notice, constituting breach of the principle of natural justice; consequence: the impugned order is quashed. The matter is remitted to the original adjudicating officer for de novo consideration after affording the taxpayer a meaningful opportunity of hearing and by taking into account the explanation and supporting documents already filed, with directions to pass a fresh reasoned order addressing the submitted representation.
Cancellation of registration was set aside for failure to consider the taxpayer's uploaded reply to the show-cause notice, constituting breach of the principle of natural justice; consequence: the impugned order is quashed. The matter is remitted to the original adjudicating officer for de novo consideration after affording the taxpayer a meaningful opportunity of hearing and by taking into account the explanation and supporting documents already filed, with directions to pass a fresh reasoned order addressing the submitted representation.
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