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...
Validity of a final assessment under section 144C(13) hinges on the applicable limitation period, and the article explains that limitation must be determined by reading section 144C with section 153 together because both provisions overlap and are interdependent. Following precedent from a High Court and an ITAT decision, the note records that a final assessment for the specified year was treated as timebarred when limitation under section 153 read with section 144C was applied, resulting in quashing of the order, while parties retain liberty to revive the appeal pending the Supreme Court largerbench decision on the issue.
Validity of a final assessment under section 144C(13) hinges on the applicable limitation period, and the article explains that limitation must be determined by reading section 144C with section 153 together because both provisions overlap and are interdependent. Following precedent from a High Court and an ITAT decision, the note records that a final assessment for the specified year was treated as timebarred when limitation under section 153 read with section 144C was applied, resulting in quashing of the order, while parties retain liberty to revive the appeal pending the Supreme Court largerbench decision on the issue.
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