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...
Revision jurisdiction was contested where revenue sought to revise an assessment by treating purchases as bogus. Tribunal found the assessing officer had issued statutory notices, conducted inquiries including notices to suppliers, and taken a plausible view after considering submissions; therefore the revisional officer could not substitute that view under the power to correct orders deemed "prejudicial to the interests of the revenue." Clauses in Explanation 2 relied on by the revisional officer were held unsupported by facts or law, the revisional order was set aside, and the appeal decided against the revenue.
Revision jurisdiction was contested where revenue sought to revise an assessment by treating purchases as bogus. Tribunal found the assessing officer had issued statutory notices, conducted inquiries including notices to suppliers, and taken a plausible view after considering submissions; therefore the revisional officer could not substitute that view under the power to correct orders deemed "prejudicial to the interests of the revenue." Clauses in Explanation 2 relied on by the revisional officer were held unsupported by facts or law, the revisional order was set aside, and the appeal decided against the revenue.
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