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...
Service of a show cause notice must be proved before ex parte adjudication can stand; where the record did not establish service on the assessee, the SC held that the order violated natural justice and set it aside on that limited ground, granting liberty to file a reply and permitting fresh adjudication. The Court, however, rejected the challenge that the notice was vague or issued without application of mind, holding that objection to be without merit and closed for the fresh proceedings. Only the reply to the notice, and any jurisdictional plea open on the record, could be considered by the assessing officer on remand.
Service of a show cause notice must be proved before ex parte adjudication can stand; where the record did not establish service on the assessee, the SC held that the order violated natural justice and set it aside on that limited ground, granting liberty to file a reply and permitting fresh adjudication. The Court, however, rejected the challenge that the notice was vague or issued without application of mind, holding that objection to be without merit and closed for the fresh proceedings. Only the reply to the notice, and any jurisdictional plea open on the record, could be considered by the assessing officer on remand.
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