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...
Provisional attachment lapses by operation of law once the prescribed one-year period expires, so continued freezing of bank accounts cannot be sustained. On that basis, the attachment was treated as having automatically ceased, and the petitioner was allowed to operate the accounts. Separately, cash credit accounts are not liable to provisional attachment, making their freezing independently unsustainable. The bank-account freeze, including the cash credit facilities, was therefore held to have come to an end, while all other contentions were left open.
Provisional attachment lapses by operation of law once the prescribed one-year period expires, so continued freezing of bank accounts cannot be sustained. On that basis, the attachment was treated as having automatically ceased, and the petitioner was allowed to operate the accounts. Separately, cash credit accounts are not liable to provisional attachment, making their freezing independently unsustainable. The bank-account freeze, including the cash credit facilities, was therefore held to have come to an end, while all other contentions were left open.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4814 
Join Channel 
