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...
Review jurisdiction is limited to discovery of new and material evidence, an error apparent on the face of the record, or analogous sufficient reasons; review applications failed as they reargued matters already decided. The Assessing Authority lacked demonstrated competence or procedural fairness to nullify a certificate under the Income Declaration Scheme, 2016, and the declaration - supported by a Registered Valuer and tax payment - was not successfully impugned. Allegations of benami transactions rested on a retracted statement; absent independent corroborative evidence (bank records or transactional proof) provisional attachment could not be sustained. All review petitions dismissed.
Review jurisdiction is limited to discovery of new and material evidence, an error apparent on the face of the record, or analogous sufficient reasons; review applications failed as they reargued matters already decided. The Assessing Authority lacked demonstrated competence or procedural fairness to nullify a certificate under the Income Declaration Scheme, 2016, and the declaration - supported by a Registered Valuer and tax payment - was not successfully impugned. Allegations of benami transactions rested on a retracted statement; absent independent corroborative evidence (bank records or transactional proof) provisional attachment could not be sustained. All review petitions dismissed.
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