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...
Non-communication of a prior court order rendered the subsequent assessment order invalid and was set aside; the assessing officer who issued a draft order is held not at fault due to a communication gap. The transfer pricing officer has supplied relied agreements and the taxpayer is directed to file a reply by the prescribed date, after which the transfer pricing officer must pass a fresh order. All procedural timelines before the transfer pricing officer, assessing officer and dispute resolution panel are extended by sixty days, and the taxpayer is precluded from objecting to that extension.
Non-communication of a prior court order rendered the subsequent assessment order invalid and was set aside; the assessing officer who issued a draft order is held not at fault due to a communication gap. The transfer pricing officer has supplied relied agreements and the taxpayer is directed to file a reply by the prescribed date, after which the transfer pricing officer must pass a fresh order. All procedural timelines before the transfer pricing officer, assessing officer and dispute resolution panel are extended by sixty days, and the taxpayer is precluded from objecting to that extension.
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