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 an order passed before the hearing date fixed in the show cause notice, and before receipt of the petitioner's representation, violated principles of natural justice because no effective opportunity of hearing was afforded. The impugned order was quashed on that limited ground, the matter was remanded for fresh consideration after giving the petitioner an opportunity to reply and be heard, and any recovery based on the quashed order was held not to survive.
The HC held that an order passed before the hearing date fixed in the show cause notice, and before receipt of the petitioner's representation, violated principles of natural justice because no effective opportunity of hearing was afforded. The impugned order was quashed on that limited ground, the matter was remanded for fresh consideration after giving the petitioner an opportunity to reply and be heard, and any recovery based on the quashed order was held not to survive.
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