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...
Refund claims arising from an appellate order must be filed within one year from the date of that order under Section 27(1B)(b); the later filing here was therefore time-barred. The Tribunal also held that Section 26 did not apply because the case was not one of return or re-importation of exported goods, and in any event that provision contained its own time requirement, which was not met. The pending Revenue appeal did not alter the statutory limitation period. The rejection of the refund application on limitation grounds was upheld.
Refund claims arising from an appellate order must be filed within one year from the date of that order under Section 27(1B)(b); the later filing here was therefore time-barred. The Tribunal also held that Section 26 did not apply because the case was not one of return or re-importation of exported goods, and in any event that provision contained its own time requirement, which was not met. The pending Revenue appeal did not alter the statutory limitation period. The rejection of the refund application on limitation grounds was upheld.
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