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...
Service of assessment order under the statutory notice procedure was deficient where the revenue admitted upload failures on the e filing portal and claimed postal service without producing tracking proof; the tribunal applied the procedural requirement of service under Section 282 and Rule 127 and, finding no credible proof that the assessment order, computation and demand notice were served in accordance with the rules, concluded that non service caused a miscarriage of justice and allowed the taxpayer's appeal.
Service of assessment order under the statutory notice procedure was deficient where the revenue admitted upload failures on the e filing portal and claimed postal service without producing tracking proof; the tribunal applied the procedural requirement of service under Section 282 and Rule 127 and, finding no credible proof that the assessment order, computation and demand notice were served in accordance with the rules, concluded that non service caused a miscarriage of justice and allowed the taxpayer's appeal.
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