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...
Issue concerns imposition of penalty for non compliance with statutory notices and the availability of reasonable cause under the tax statute. Tribunal applied the requirement that reasonable cause be supported by contemporaneous evidence and found the medical certificate dated after the relevant notices insufficient; evidence of substantial online income and repeated failure to respond during assessment and penalty proceedings indicated casual indifference. On these grounds the Tribunal upheld the penalty for non compliance, rejecting the reasonable cause plea and confirming the penalty order for the assessment year specified.
Issue concerns imposition of penalty for non compliance with statutory notices and the availability of reasonable cause under the tax statute. Tribunal applied the requirement that reasonable cause be supported by contemporaneous evidence and found the medical certificate dated after the relevant notices insufficient; evidence of substantial online income and repeated failure to respond during assessment and penalty proceedings indicated casual indifference. On these grounds the Tribunal upheld the penalty for non compliance, rejecting the reasonable cause plea and confirming the penalty order for the assessment year specified.
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