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...
Where a show cause notice under Section 74(1) is founded on documents from an earlier search and seizure, the noticee must be given effective access to the relied upon material to answer it. The Court held that the petitioners were entitled to inspection and/or extracts of all relied upon records, and that specific accounting data such as excel or tally files had to be supplied where relied upon and specifically requested. It limited the ruling to this procedural access issue, directed disclosure within the time fixed, allowed time to reply and a personal hearing, extended the adjudication period, and left all other challenges open.
Where a show cause notice under Section 74(1) is founded on documents from an earlier search and seizure, the noticee must be given effective access to the relied upon material to answer it. The Court held that the petitioners were entitled to inspection and/or extracts of all relied upon records, and that specific accounting data such as excel or tally files had to be supplied where relied upon and specifically requested. It limited the ruling to this procedural access issue, directed disclosure within the time fixed, allowed time to reply and a personal hearing, extended the adjudication period, and left all other challenges open.
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