Effective service requirement: officers must explore alternative service modes beyond the GST portal and afford personal hearing; non-compliance voids...
Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Refund could not be denied merely because the Chartered Accountant's certificate was not in the prescribed format or did not mention the year, where the lower authority did not question the genuineness of the claim and the defect was only formal. The Tribunal held that the Board circular format was only indicative, not mandatory, and that substantial compliance was sufficient. The rejection of refund on this technical ground was therefore unsustainable. The common appellate order was set aside and the appeals were allowed with consequential benefits as per law.
Refund could not be denied merely because the Chartered Accountant's certificate was not in the prescribed format or did not mention the year, where the lower authority did not question the genuineness of the claim and the defect was only formal. The Tribunal held that the Board circular format was only indicative, not mandatory, and that substantial compliance was sufficient. The rejection of refund on this technical ground was therefore unsustainable. The common appellate order was set aside and the appeals were allowed with consequential benefits as per law.
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