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...
A writ challenge to a notice initiating revision under Section 108 was held premature because no final revisional order had yet been passed. The High Court left open the petitioner's objections on jurisdiction and maintainability to be raised before the revisional authority and declined interference at the threshold. At the same time, it protected the petitioner by directing conditional release of the goods pending revision, subject to an additional deposit, filing of an affidavit undertaking to abide by the revisional order, and participation in the revisional proceedings. The writ petition was disposed of without examining the merits of the revision challenge.
A writ challenge to a notice initiating revision under Section 108 was held premature because no final revisional order had yet been passed. The High Court left open the petitioner's objections on jurisdiction and maintainability to be raised before the revisional authority and declined interference at the threshold. At the same time, it protected the petitioner by directing conditional release of the goods pending revision, subject to an additional deposit, filing of an affidavit undertaking to abide by the revisional order, and participation in the revisional proceedings. The writ petition was disposed of without examining the merits of the revision challenge.
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