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 High Court held that the petitioner should be given an opportunity to place a legible copy of the Bill of Lading and any other required documents before the appellate authority, where the refund claim had been rejected because the document was illegible and the shipping-line contention was treated as unsubstantiated. The matter was directed to be reconsidered afresh on merits after permitting production of the legible Bill of Lading and supporting material, reflecting the application of natural justice in the refund appeal process.
The High Court held that the petitioner should be given an opportunity to place a legible copy of the Bill of Lading and any other required documents before the appellate authority, where the refund claim had been rejected because the document was illegible and the shipping-line contention was treated as unsubstantiated. The matter was directed to be reconsidered afresh on merits after permitting production of the legible Bill of Lading and supporting material, reflecting the application of natural justice in the refund appeal process.
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