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...
Reassessment based on the same interest income and TDS mismatch material already examined in final appellate proceedings was held to be an impermissible change of opinion. The sanction note disclosed no fresh tangible information, new ground, or subsequent material suggesting escapement of income, so reopening under Section 148 amounted to a collateral attack on a concluded determination. On that basis, the HC found the assumption of jurisdiction unsustainable and quashed the notice, sanction note, and consequential proceedings.
Reassessment based on the same interest income and TDS mismatch material already examined in final appellate proceedings was held to be an impermissible change of opinion. The sanction note disclosed no fresh tangible information, new ground, or subsequent material suggesting escapement of income, so reopening under Section 148 amounted to a collateral attack on a concluded determination. On that basis, the HC found the assumption of jurisdiction unsustainable and quashed the notice, sanction note, and consequential proceedings.
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