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Section 62(2) was applied to hold that an assessment made for non-filing of returns stands automatically withdrawn when the registered person files the returns for the relevant period and pays the tax, interest and late fee. On the petitioner's assertion that these requirements had been met, the assessment order was treated as deemed withdrawn, so recovery steps founded on it, including garnishee proceedings, could not continue. The relief was made subject to verification by the authorities of the date of filing and payment of the dues.
Section 62(2) was applied to hold that an assessment made for non-filing of returns stands automatically withdrawn when the registered person files the returns for the relevant period and pays the tax, interest and late fee. On the petitioner's assertion that these requirements had been met, the assessment order was treated as deemed withdrawn, so recovery steps founded on it, including garnishee proceedings, could not continue. The relief was made subject to verification by the authorities of the date of filing and payment of the dues.
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