SEZ unit exempt from service tax on manpower supply; overseas employers deemed employers; limitation invocation unjustified; directors' remuneration n...
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The HC found that the SCN was served on the authorized registered email beyond the prescribed period under s.73(2) read with s.73(10) CGST Act and that the adjudicating authority failed to consider the majority of the Petitioner's submissions and disregarded relevant precedent, thereby breaching principles of natural justice. The Court noted the Department knew the authorized email had changed and that service on the new address occurred after the limitation period, rendering the SCN prima facie time-barred. The Petitioner established a strong prima facie case for interim relief; the operation of the impugned order was stayed pending admission, and the matter was adjourned to 20 Nov 2025.
The HC found that the SCN was served on the authorized registered email beyond the prescribed period under s.73(2) read with s.73(10) CGST Act and that the adjudicating authority failed to consider the majority of the Petitioner's submissions and disregarded relevant precedent, thereby breaching principles of natural justice. The Court noted the Department knew the authorized email had changed and that service on the new address occurred after the limitation period, rendering the SCN prima facie time-barred. The Petitioner established a strong prima facie case for interim relief; the operation of the impugned order was stayed pending admission, and the matter was adjourned to 20 Nov 2025.
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