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...
Condonation of delay and limitation for preferring statutory appeals was determinative: the appellate forum found repeated adjournments and that the appeal was filed after the condonable period, so the Commissioner (Appeal) correctly held the appeal time-barred and dismissed it. The tribunal applied the proviso limiting discretionary exemptions in appeals and relied on the Supreme Court precedent that the Commissioner cannot condone delay beyond the short statutory condonation window, producing dismissal on limitation grounds. Forum shopping and invocation of writ jurisdiction were noted but did not alter the limitation outcome.
Condonation of delay and limitation for preferring statutory appeals was determinative: the appellate forum found repeated adjournments and that the appeal was filed after the condonable period, so the Commissioner (Appeal) correctly held the appeal time-barred and dismissed it. The tribunal applied the proviso limiting discretionary exemptions in appeals and relied on the Supreme Court precedent that the Commissioner cannot condone delay beyond the short statutory condonation window, producing dismissal on limitation grounds. Forum shopping and invocation of writ jurisdiction were noted but did not alter the limitation outcome.
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