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...
Rectification proceedings and assessment dispute concerning a tax demand were addressed by conditioning interim relief on a partial deposit: the taxpayer must deposit 25% of the disputed tax and have no other outstanding tax arrears for the bank attachment to be vacated. The appellate authority is permitted to decide the statutory appeal on merits even if limitation issues exist, provided the appeal is filed within the prescribed period. Failure to comply with the stipulated conditions permits the tax authority to resume recovery as if the petition were dismissed. Writ petition disposed accordingly.
Rectification proceedings and assessment dispute concerning a tax demand were addressed by conditioning interim relief on a partial deposit: the taxpayer must deposit 25% of the disputed tax and have no other outstanding tax arrears for the bank attachment to be vacated. The appellate authority is permitted to decide the statutory appeal on merits even if limitation issues exist, provided the appeal is filed within the prescribed period. Failure to comply with the stipulated conditions permits the tax authority to resume recovery as if the petition were dismissed. Writ petition disposed accordingly.
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