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...
Vagueness of the show cause notice and breach of natural justice were held decisive: the Order in Original relied on material and findings beyond the scope of the notice without specifying how that material prima facie established contraventions of the Customs Brokers Licensing Regulations, thereby offending principles of natural justice. The Tribunal's finding that the order travelled beyond the notice was sustained. Because the issue was procedural and factual, no substantial question of law arose for appellate review under the statutory appeal provision, and the appeal was dismissed.
Vagueness of the show cause notice and breach of natural justice were held decisive: the Order in Original relied on material and findings beyond the scope of the notice without specifying how that material prima facie established contraventions of the Customs Brokers Licensing Regulations, thereby offending principles of natural justice. The Tribunal's finding that the order travelled beyond the notice was sustained. Because the issue was procedural and factual, no substantial question of law arose for appellate review under the statutory appeal provision, and the appeal was dismissed.
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