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...
Non-incorporation of the Document Identification Number required by the Board circulars rendered the appellate order invalid, as earlier decisions had treated DIN compliance as mandatory and failure to include it as fatal to the order's validity. The contention that the requirement applied only to communications and not to adjudicatory or appellate orders was rejected, because later precedent had extended the same consequence to such orders. A subsequent circular relaxing the requirement for email-communicated orders did not assist the respondent, since it came into force after the impugned order and, in any event, the alternative Unique Issue Number was also not used. The appellate order was set aside and the matter remanded for fresh consideration after hearing the petitioner.
Non-incorporation of the Document Identification Number required by the Board circulars rendered the appellate order invalid, as earlier decisions had treated DIN compliance as mandatory and failure to include it as fatal to the order's validity. The contention that the requirement applied only to communications and not to adjudicatory or appellate orders was rejected, because later precedent had extended the same consequence to such orders. A subsequent circular relaxing the requirement for email-communicated orders did not assist the respondent, since it came into force after the impugned order and, in any event, the alternative Unique Issue Number was also not used. The appellate order was set aside and the matter remanded for fresh consideration after hearing the petitioner.
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