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...
Blocking of the electronic credit ledger must be accompanied by written reasons and followed by opportunity to be heard; the respondent may issue a show cause notice after receipt of an investigation report and must communicate recorded reasons to the taxpayer. The taxpayer may file a reply with additional documentary evidence within one week of receiving the order; the respondent must then fix a personal hearing and decide either to revoke the blocking or issue a speaking order explaining rejection. Timelines: decision within two weeks after reply, or within three weeks if no reply is filed.
Blocking of the electronic credit ledger must be accompanied by written reasons and followed by opportunity to be heard; the respondent may issue a show cause notice after receipt of an investigation report and must communicate recorded reasons to the taxpayer. The taxpayer may file a reply with additional documentary evidence within one week of receiving the order; the respondent must then fix a personal hearing and decide either to revoke the blocking or issue a speaking order explaining rejection. Timelines: decision within two weeks after reply, or within three weeks if no reply is filed.
Note: It is a system-generated summary and is for quick reference only.
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