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...
Penalty for failure to comply with statutory notices was set aside because notices issued via the tax portal were not communicated and an exparte assessment under the notice scheme was passed. The assessee activated an efiling account only after the assessment order and became aware of proceedings later; the appellate authority condoned delay in filing the appeal and reopened the assessment. The tribunal found that noncommunication amounted to a reasonable cause for noncompliance and deleted the penalty. Appeal by the revenue was dismissed and penalty removed.
Penalty for failure to comply with statutory notices was set aside because notices issued via the tax portal were not communicated and an exparte assessment under the notice scheme was passed. The assessee activated an efiling account only after the assessment order and became aware of proceedings later; the appellate authority condoned delay in filing the appeal and reopened the assessment. The tribunal found that noncommunication amounted to a reasonable cause for noncompliance and deleted the penalty. Appeal by the revenue was dismissed and penalty removed.
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