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...
The Court permitted amendment of the writ petition to join Daiwa Securities Group INC as a necessary and affected party, reasoning that an adverse outcome on the Department's case would directly affect that entity; the amendment must be filed within two weeks of order upload, re verification is dispensed with, and service on the newly joined respondent must be effected so as to be returnable on the listed date. The operative effect is mandatory joinder with fixed timelines for amendment and service and placement of the matter on board for directions on the returnable date.
The Court permitted amendment of the writ petition to join Daiwa Securities Group INC as a necessary and affected party, reasoning that an adverse outcome on the Department's case would directly affect that entity; the amendment must be filed within two weeks of order upload, re verification is dispensed with, and service on the newly joined respondent must be effected so as to be returnable on the listed date. The operative effect is mandatory joinder with fixed timelines for amendment and service and placement of the matter on board for directions on the returnable date.
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