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...
Section 107(4) gives the Appellate Authority discretion to admit an appeal within the additional one-month condonable period if sufficient cause prevented timely filing. Where an appeal is presented within that period, the authority must examine the explanation for delay on its merits, including uncertainty created by overlapping statutory changes and portal-related constraints. Rejection as time-barred without properly considering that explanation is unsustainable. The appeal was therefore restored for fresh consideration on merits.
Section 107(4) gives the Appellate Authority discretion to admit an appeal within the additional one-month condonable period if sufficient cause prevented timely filing. Where an appeal is presented within that period, the authority must examine the explanation for delay on its merits, including uncertainty created by overlapping statutory changes and portal-related constraints. Rejection as time-barred without properly considering that explanation is unsustainable. The appeal was therefore restored for fresh consideration on merits.
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