Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
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The High Court dismissed the petition challenging the show cause notice issued u/s 74 of the Central Goods and Services Tax Act, 2017. The court found no justification for alleging suppression or invoking the extended period of limitation. The show cause notice was based on findings from investigations after the audit report. The petitioner's statements accepting its status as a payment aggregator were considered relevant. The court held that at the show cause notice stage, judicial review is extremely narrow, and defences can be raised in response. Interference is warranted only in cases of violation of fundamental rights, natural justice, or lack of jurisdiction, which were not established here. The petitioner was directed to respond to the show cause notice and raise all defences.
The High Court dismissed the petition challenging the show cause notice issued u/s 74 of the Central Goods and Services Tax Act, 2017. The court found no justification for alleging suppression or invoking the extended period of limitation. The show cause notice was based on findings from investigations after the audit report. The petitioner's statements accepting its status as a payment aggregator were considered relevant. The court held that at the show cause notice stage, judicial review is extremely narrow, and defences can be raised in response. Interference is warranted only in cases of violation of fundamental rights, natural justice, or lack of jurisdiction, which were not established here. The petitioner was directed to respond to the show cause notice and raise all defences.
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