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...
Imposition of a general penalty where concurrent assessment orders exist was held arbitrary under the doctrine against double punishment; consequence: the general penalty of Rs.50,000 was set aside. The liability for late fee was sustained on merits and the petitioner was directed to pay Rs.1,67,200 within 30 days; consequence: on compliance the impugned assessment order and recovery proceedings will be quashed and dropped immediately. Failure to comply permits recovery as if the petition were dismissed. Writ Petition disposed accordingly.
Imposition of a general penalty where concurrent assessment orders exist was held arbitrary under the doctrine against double punishment; consequence: the general penalty of Rs.50,000 was set aside. The liability for late fee was sustained on merits and the petitioner was directed to pay Rs.1,67,200 within 30 days; consequence: on compliance the impugned assessment order and recovery proceedings will be quashed and dropped immediately. Failure to comply permits recovery as if the petition were dismissed. Writ Petition disposed accordingly.
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