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...
Determination turns on whether electronic debit or challan generation marks the payment date for advance tax. The tribunal found that an electronic netbanking debit reflected in the taxpayer's bank statement on the statutory due date constitutes payment; delay in generation/credit of the challan due to bank/technical processes is beyond the taxpayer's control. The presumption that payment was timely stands unless Revenue proves otherwise. Consequently, interest under advancetax delay provisions was not leviable and the relief was granted to the taxpayer.
Determination turns on whether electronic debit or challan generation marks the payment date for advance tax. The tribunal found that an electronic netbanking debit reflected in the taxpayer's bank statement on the statutory due date constitutes payment; delay in generation/credit of the challan due to bank/technical processes is beyond the taxpayer's control. The presumption that payment was timely stands unless Revenue proves otherwise. Consequently, interest under advancetax delay provisions was not leviable and the relief was granted to the taxpayer.
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