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...
Determination of the limitation period for passing final transfer-pricing assessment under section 144C(13) was contested with respect to its interplay with section 153. The tribunal noted higher-court precedent holding the two provisions are interdependent and limitation must be determined with reference to section 144C read with section 153; applying that approach, the tribunal found final assessment orders were passed beyond the applicable limitation period and therefore lacked jurisdiction. Consequently, the impugned final assessment orders were quashed for being time-barred.
Determination of the limitation period for passing final transfer-pricing assessment under section 144C(13) was contested with respect to its interplay with section 153. The tribunal noted higher-court precedent holding the two provisions are interdependent and limitation must be determined with reference to section 144C read with section 153; applying that approach, the tribunal found final assessment orders were passed beyond the applicable limitation period and therefore lacked jurisdiction. Consequently, the impugned final assessment orders were quashed for being time-barred.
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