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...
Reopening of assessment under Section 147 before the 01.04.2021 amendments requires only that the notice under Section 148 be issued within the limitation period; service within that period is not a jurisdictional prerequisite. The date of dispatch governs validity of issuance, so a notice issued on 31.03.2019 remains effective even if actual service occurred later. Applying that rule, the reassessment proceedings were not vitiated by delayed service or an accompanying attachment error, and the writ challenging the reassessment was dismissed.
Reopening of assessment under Section 147 before the 01.04.2021 amendments requires only that the notice under Section 148 be issued within the limitation period; service within that period is not a jurisdictional prerequisite. The date of dispatch governs validity of issuance, so a notice issued on 31.03.2019 remains effective even if actual service occurred later. Applying that rule, the reassessment proceedings were not vitiated by delayed service or an accompanying attachment error, and the writ challenging the reassessment was dismissed.
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