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...
Tribunal misapplied procedural law by referring to an incorrect provision and failed to consider the petitioner's supporting affidavit; consequently the High Court quashed the Miscellaneous Application order and recalled the Tribunal's earlier order. The Tribunal's adverse finding that the petitioner offered a "cooked story" was held to be baseless and contrary to record; accordingly the delay in filing cross objections is condoned on the affidavit averments and the cross objections are directed to be heard. Because the appeal and cross objections have been pending long, the Tribunal is ordered to decide both together within 12 weeks.
Tribunal misapplied procedural law by referring to an incorrect provision and failed to consider the petitioner's supporting affidavit; consequently the High Court quashed the Miscellaneous Application order and recalled the Tribunal's earlier order. The Tribunal's adverse finding that the petitioner offered a "cooked story" was held to be baseless and contrary to record; accordingly the delay in filing cross objections is condoned on the affidavit averments and the cross objections are directed to be heard. Because the appeal and cross objections have been pending long, the Tribunal is ordered to decide both together within 12 weeks.
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