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...
VCES declaration rejection could not be sustained where the notice proposing rejection was issued beyond the prescribed thirty-day period, including when measured from the circular clarifying its application to declarations already filed. The Tribunal noted that the department's reliance on general correspondence indicated only a roving inquiry, not a proper basis for rejection. As the department was bound by its own circulars, the order upholding rejection of the declaration under the Voluntary Compliance Encouragement Scheme, 2013 was set aside and the appeal was allowed with consequential relief.
VCES declaration rejection could not be sustained where the notice proposing rejection was issued beyond the prescribed thirty-day period, including when measured from the circular clarifying its application to declarations already filed. The Tribunal noted that the department's reliance on general correspondence indicated only a roving inquiry, not a proper basis for rejection. As the department was bound by its own circulars, the order upholding rejection of the declaration under the Voluntary Compliance Encouragement Scheme, 2013 was set aside and the appeal was allowed with consequential relief.
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