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 composite show cause notice under Section 74 clubbing multiple financial years was held impermissible because the statutory scheme operates tax period-wise and year-wise, with separate return obligations and limitation consequences for each period. The Court followed its own binding precedent and held that authorities within its jurisdiction were bound by that view until stayed or overruled; dismissal in limine of a contrary challenge did not create merger on merits. The composite notice and consequential order were quashed, with liberty to issue a fresh notice strictly in accordance with law.
A composite show cause notice under Section 74 clubbing multiple financial years was held impermissible because the statutory scheme operates tax period-wise and year-wise, with separate return obligations and limitation consequences for each period. The Court followed its own binding precedent and held that authorities within its jurisdiction were bound by that view until stayed or overruled; dismissal in limine of a contrary challenge did not create merger on merits. The composite notice and consequential order were quashed, with liberty to issue a fresh notice strictly in accordance with law.
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