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...
A sanctioned scheme of demerger vests specified assets in the resulting companies; those vested assets cannot be attached to satisfy the tax liability of the demerged transferor. The attachment impugned was held unsustainable as it targeted property vested in a resulting company, but the tax authority remains competent to attach those vested assets independently to recover the resulting company's own Wealth Tax liability. The petitioner is protected from penal consequences while statutory appeals filed under the Wealth Tax Act remain pending. Writ petition partly allowed with liberty as stated.
A sanctioned scheme of demerger vests specified assets in the resulting companies; those vested assets cannot be attached to satisfy the tax liability of the demerged transferor. The attachment impugned was held unsustainable as it targeted property vested in a resulting company, but the tax authority remains competent to attach those vested assets independently to recover the resulting company's own Wealth Tax liability. The petitioner is protected from penal consequences while statutory appeals filed under the Wealth Tax Act remain pending. Writ petition partly allowed with liberty as stated.
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