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 HC held that rejection of the statutory appeal on jurisdictional grounds was a departmental mistake where the office lacked a system to transmit the appeal to the correct appellate authority. Treating the defect as procedural rather than substantive, the Court set aside the impugned appellate order without examining the merits of the underlying dispute. The appeal was restored and directed to be transmitted to the competent appellate authority for consideration in accordance with law.
The HC held that rejection of the statutory appeal on jurisdictional grounds was a departmental mistake where the office lacked a system to transmit the appeal to the correct appellate authority. Treating the defect as procedural rather than substantive, the Court set aside the impugned appellate order without examining the merits of the underlying dispute. The appeal was restored and directed to be transmitted to the competent appellate authority for consideration in accordance with law.
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