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: imposition of penalty under section 271(1)(b) for failure to comply with notices under section 142(1). Principle applied: the onus lies on the assessee to show bona fide and reasonable cause and to disclose material facts; Revenue need not prove deliberate default. Outcome: where the assessee offered no substantiated explanation and assessment proceeded ex parte, subsequent belated compliance did not negate penalty. The ITAT upheld two penalties for separate non compliance occasions and dismissed the appeal for failure to prove reasonable cause.
Issue: imposition of penalty under section 271(1)(b) for failure to comply with notices under section 142(1). Principle applied: the onus lies on the assessee to show bona fide and reasonable cause and to disclose material facts; Revenue need not prove deliberate default. Outcome: where the assessee offered no substantiated explanation and assessment proceeded ex parte, subsequent belated compliance did not negate penalty. The ITAT upheld two penalties for separate non compliance occasions and dismissed the appeal for failure to prove reasonable cause.
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