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...
The note addresses whether limitation for passing a final assessment under section 144C(13) must be measured solely by section 144C or with reference to section 153; applying the reasoning of prior precedents it concludes the limitation period is to be determined read with section 153, making the final assessment order u/s 143(3) r.w.s.144C(13) for AY 2020-21 time barred. The operative effect is quashing of that final assessment order. Parties are granted liberty to revive the appeal on merits if the Supreme Court Larger Bench alters the law on this limitation issue.
The note addresses whether limitation for passing a final assessment under section 144C(13) must be measured solely by section 144C or with reference to section 153; applying the reasoning of prior precedents it concludes the limitation period is to be determined read with section 153, making the final assessment order u/s 143(3) r.w.s.144C(13) for AY 2020-21 time barred. The operative effect is quashing of that final assessment order. Parties are granted liberty to revive the appeal on merits if the Supreme Court Larger Bench alters the law on this limitation issue.
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