Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Non-consideration of reply given pursuant to GST DRC-01A notice violates principles of natural justice. Rule 142(1A) merely allows proper officer discretion to issue communication, not adjudicate submissions. Right of assessee arises only after show cause notice u/r 142(1)(a) with hearing opportunity. Affording hearing at different stages not contemplated by legislature. Taxing statutes strictly construed without implying equity or hardship considerations. Since only communication issued, no grounds to entertain writ petition filed to stall pending proceedings. Writ petition dismissed.
Non-consideration of reply given pursuant to GST DRC-01A notice violates principles of natural justice. Rule 142(1A) merely allows proper officer discretion to issue communication, not adjudicate submissions. Right of assessee arises only after show cause notice u/r 142(1)(a) with hearing opportunity. Affording hearing at different stages not contemplated by legislature. Taxing statutes strictly construed without implying equity or hardship considerations. Since only communication issued, no grounds to entertain writ petition filed to stall pending proceedings. Writ petition dismissed.
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