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...
Application maintainability was questioned where the applicant initially failed to produce purchase and sales invoices and product brochure; the appellate power to confirm or modify an advance ruling exists but no merits determination was possible on the record. The applicant subsequently furnished invoices and offered further documents at hearing; those materials require factual verification and assessment for relevance. The appellate body set aside the impugned non maintainability ruling and remanded the matter to the Advance Ruling Authority for fresh examination and decision in light of the newly produced records.
Application maintainability was questioned where the applicant initially failed to produce purchase and sales invoices and product brochure; the appellate power to confirm or modify an advance ruling exists but no merits determination was possible on the record. The applicant subsequently furnished invoices and offered further documents at hearing; those materials require factual verification and assessment for relevance. The appellate body set aside the impugned non maintainability ruling and remanded the matter to the Advance Ruling Authority for fresh examination and decision in light of the newly produced records.
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