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...
Admissibility of appeal requires existence of an original return; where an original return under the normal return provision was filed and processed, absence of a return in response to a notice does not permit dismissal under the provision applied by the first appellate authority, so the dismissal was set aside. Advance tax is payable only on estimated and admitted income; requiring payment in respect of disputed or ex parte additions as a precondition to admit an appeal is impermissible. Matter is remitted for fresh assessment after affording the assessee an opportunity to be heard and considering submissions and evidence.
Admissibility of appeal requires existence of an original return; where an original return under the normal return provision was filed and processed, absence of a return in response to a notice does not permit dismissal under the provision applied by the first appellate authority, so the dismissal was set aside. Advance tax is payable only on estimated and admitted income; requiring payment in respect of disputed or ex parte additions as a precondition to admit an appeal is impermissible. Matter is remitted for fresh assessment after affording the assessee an opportunity to be heard and considering submissions and evidence.
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