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...
An unsigned notice issued under section 143(2) was held invalid because signing in electronic form was treated as a mandatory requirement under section 282A(1), not a mere formality. As the notice was void ab initio, it could not confer jurisdiction on the AO to complete scrutiny assessment under section 143(3). The assessment was therefore quashed, and the merits grounds were left academic and not examined.
An unsigned notice issued under section 143(2) was held invalid because signing in electronic form was treated as a mandatory requirement under section 282A(1), not a mere formality. As the notice was void ab initio, it could not confer jurisdiction on the AO to complete scrutiny assessment under section 143(3). The assessment was therefore quashed, and the merits grounds were left academic and not examined.
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