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...
Absence of a DIN in a GST assessment order was treated as a patent defect sufficient to invalidate the order. Although the writ petitions were delayed, the court noted practical difficulties with electronic portal service under the GST regime and held that such delayed challenges to patently irregular orders could still be entertained subject to deposit of 20% of the disputed tax. The impugned assessment was set aside and the matter remanded for fresh assessment after due hearing, with any amount already paid or recovered adjusted against the required deposit and the pendency period excluded for limitation purposes.
Absence of a DIN in a GST assessment order was treated as a patent defect sufficient to invalidate the order. Although the writ petitions were delayed, the court noted practical difficulties with electronic portal service under the GST regime and held that such delayed challenges to patently irregular orders could still be entertained subject to deposit of 20% of the disputed tax. The impugned assessment was set aside and the matter remanded for fresh assessment after due hearing, with any amount already paid or recovered adjusted against the required deposit and the pendency period excluded for limitation purposes.
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