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...
Appeal under Section 260A is confined to substantial questions of law and does not permit re appreciation of evidence or concurrent findings of fact; appeal dismissed to the extent it sought such re examination. The Revenue discharged its initial burden by issuing notices to counterparties and obtaining denials or non service, which constituted substantial evidence and shifted the onus to the appellant to produce creditworthy documents or witnesses; appellant failed to do so, so findings of bogus transactions were supportable. No procedural prejudice was shown as there is no record of a refused request to cross examine and the appellant did not produce parties or evidence.
Appeal under Section 260A is confined to substantial questions of law and does not permit re appreciation of evidence or concurrent findings of fact; appeal dismissed to the extent it sought such re examination. The Revenue discharged its initial burden by issuing notices to counterparties and obtaining denials or non service, which constituted substantial evidence and shifted the onus to the appellant to produce creditworthy documents or witnesses; appellant failed to do so, so findings of bogus transactions were supportable. No procedural prejudice was shown as there is no record of a refused request to cross examine and the appellant did not produce parties or evidence.
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