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...
Show cause notices must quantify interest liability before demanding it; failure to quantify interest for the specified period in the notice violated the statutory requirement and rendered both the notice and subsequent adjudication order invalid. The court distinguished liability quantified in orders from liability that must be specified in notices, holding that provisions addressing unquantified interest in orders do not cure an unquantified notice. Consequently the impugned notice and demand were quashed, with liberty for tax authorities to issue a fresh, properly quantified show cause notice and proceed in accordance with law.
Show cause notices must quantify interest liability before demanding it; failure to quantify interest for the specified period in the notice violated the statutory requirement and rendered both the notice and subsequent adjudication order invalid. The court distinguished liability quantified in orders from liability that must be specified in notices, holding that provisions addressing unquantified interest in orders do not cure an unquantified notice. Consequently the impugned notice and demand were quashed, with liberty for tax authorities to issue a fresh, properly quantified show cause notice and proceed in accordance with law.
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