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 power to admit belated additional grounds was upheld where those grounds go to the root of the dispute and all relevant facts are already on record; accordingly the tribunal admitted the assessee's additional ground. Reopening of assessment was held invalid because the reassessment was initiated solely on specified cash deposits yet the assessing officer made an unrelated addition by disallowing an exemption that was not part of the recorded reasons for reopening; since the addition did not flow from the recorded reasons, the reopening was quashed and the appeal allowed.
Tribunal power to admit belated additional grounds was upheld where those grounds go to the root of the dispute and all relevant facts are already on record; accordingly the tribunal admitted the assessee's additional ground. Reopening of assessment was held invalid because the reassessment was initiated solely on specified cash deposits yet the assessing officer made an unrelated addition by disallowing an exemption that was not part of the recorded reasons for reopening; since the addition did not flow from the recorded reasons, the reopening was quashed and the appeal allowed.
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