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 article addresses maintainability of appeals under the proviso to Section 129A(1), holding that the Tribunal may exercise discretion to refuse admission where the penalty determined by the impugned order falls below the monetary threshold of two lakh rupees; accordingly the appeals were dismissed as not maintainable. It also affirms a legal presumption of service under the General Clauses Act, treating speed-post dispatch as delivery and finding no rebuttal to delay/limitation objections. The Tribunal did not consider the merits of the penalty, and its dismissal does not approve the penalty imposed.
The article addresses maintainability of appeals under the proviso to Section 129A(1), holding that the Tribunal may exercise discretion to refuse admission where the penalty determined by the impugned order falls below the monetary threshold of two lakh rupees; accordingly the appeals were dismissed as not maintainable. It also affirms a legal presumption of service under the General Clauses Act, treating speed-post dispatch as delivery and finding no rebuttal to delay/limitation objections. The Tribunal did not consider the merits of the penalty, and its dismissal does not approve the penalty imposed.
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