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...
Interest income on non-performing assets was treated as taxable where the taxpayer both accrued interest and made substantial fresh advances to the same borrowers; the court held that such conduct negates a claim that accrued interest was merely notional and uncollectible, and therefore supports taxation. The writ was held non-maintainable because an effective statutory appellate remedy existed and was not timely availed, so the High Court refused to substitute writ jurisdiction for the lapsed appeal. The tribunal's fact-driven distinction between loan categories based on borrower conduct and fresh advances was upheld, favouring revenue on the merits.
Interest income on non-performing assets was treated as taxable where the taxpayer both accrued interest and made substantial fresh advances to the same borrowers; the court held that such conduct negates a claim that accrued interest was merely notional and uncollectible, and therefore supports taxation. The writ was held non-maintainable because an effective statutory appellate remedy existed and was not timely availed, so the High Court refused to substitute writ jurisdiction for the lapsed appeal. The tribunal's fact-driven distinction between loan categories based on borrower conduct and fresh advances was upheld, favouring revenue on the merits.
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