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...
A certificate issued under the withholding regime is effective for the entire assessment year specified, not only prospectively from its issuance; construing the statutory provisions and Rule 28AA(2), the certificate remains operative throughout that assessment year unless earlier cancelled. Applying that rule, a deductor who relied on a valid certificate for the assessment year cannot be treated as an assessee in default for lower deduction, and consequential interest charged on that basis is not leviable where the certificate stood in force and was not cancelled.
A certificate issued under the withholding regime is effective for the entire assessment year specified, not only prospectively from its issuance; construing the statutory provisions and Rule 28AA(2), the certificate remains operative throughout that assessment year unless earlier cancelled. Applying that rule, a deductor who relied on a valid certificate for the assessment year cannot be treated as an assessee in default for lower deduction, and consequential interest charged on that basis is not leviable where the certificate stood in force and was not cancelled.
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