Effective service requirement: officers must explore alternative service modes beyond the GST portal and afford personal hearing; non-compliance voids...
Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Reassessment under section 148 requires prima facie material that can link the assessee to the alleged escaped income; the expressions "relates to" and "pertains to" in Explanation 2 cannot be read in isolation. The revenue must examine seized material with surrounding circumstances and record its relevance to the assessee. Where the relied-upon document is vague, unspecific, names another person, and is connected only by later collateral information, no live nexus is established. In such circumstances, reopening is based on conjecture and is unsustainable, and the reopening notices and consequential assessment orders are liable to be quashed.
Reassessment under section 148 requires prima facie material that can link the assessee to the alleged escaped income; the expressions "relates to" and "pertains to" in Explanation 2 cannot be read in isolation. The revenue must examine seized material with surrounding circumstances and record its relevance to the assessee. Where the relied-upon document is vague, unspecific, names another person, and is connected only by later collateral information, no live nexus is established. In such circumstances, reopening is based on conjecture and is unsustainable, and the reopening notices and consequential assessment orders are liable to be quashed.
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