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...
Provisional attachment under the Act expires after one year, and an attachment directed by reference to a PAN does not automatically operate on a separate savings bank account absent a specific attachment order for that account; consequently the provisional attachment in relation to the petitioner's savings account is nonoperational as the oneyear period has lapsed. The High Court held that no justifying order specifically attaching the savings account appears on record, and therefore partly allowed the petition and disposed of pending applications accordingly.
Provisional attachment under the Act expires after one year, and an attachment directed by reference to a PAN does not automatically operate on a separate savings bank account absent a specific attachment order for that account; consequently the provisional attachment in relation to the petitioner's savings account is nonoperational as the oneyear period has lapsed. The High Court held that no justifying order specifically attaching the savings account appears on record, and therefore partly allowed the petition and disposed of pending applications accordingly.
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