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...
The HC set aside orders cancelling GST registrations under CGST/SGST Acts 2017, finding procedural violations by the Proper Officer. The court determined that cancellation under Section 29(2) requires proper notice and meaningful opportunity for hearing per Rule 22, not mere formality. Despite petitioners' failure to respond to show cause notices, the impugned orders erroneously referenced non-existent replies, rendering the proceedings defective. While revocation applications were time-barred (exceeding 270 days under Rule 23), the court intervened due to jurisdictional errors. The registrations were restored with conditions, including extended deadlines for filing annual returns except for 2024-2025, which remains governed by Section 44 requirements.
The HC set aside orders cancelling GST registrations under CGST/SGST Acts 2017, finding procedural violations by the Proper Officer. The court determined that cancellation under Section 29(2) requires proper notice and meaningful opportunity for hearing per Rule 22, not mere formality. Despite petitioners' failure to respond to show cause notices, the impugned orders erroneously referenced non-existent replies, rendering the proceedings defective. While revocation applications were time-barred (exceeding 270 days under Rule 23), the court intervened due to jurisdictional errors. The registrations were restored with conditions, including extended deadlines for filing annual returns except for 2024-2025, which remains governed by Section 44 requirements.
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