Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Whether the impugned supplies qualified as export of services under Section 2(6) IGST and whether the petitioner was an "intermediary" under Section 13(2)/place of supply under Section 13(8)(b) was the dominant issue. The court held the authorities failed to make requisite findings on (a) existence of a third party intermeddling in transactions, (b) whether supplies were between two principals or by the petitioner on its own account, and (c) whether the petitioner merely arranged/facilitated supplies; their orders were cryptic and showed non-application of mind. Consequence: impugned orders set aside and matter remanded to appellate and refund sanctioning authorities for fresh decision. - HC
Whether the impugned supplies qualified as export of services under Section 2(6) IGST and whether the petitioner was an "intermediary" under Section 13(2)/place of supply under Section 13(8)(b) was the dominant issue. The court held the authorities failed to make requisite findings on (a) existence of a third party intermeddling in transactions, (b) whether supplies were between two principals or by the petitioner on its own account, and (c) whether the petitioner merely arranged/facilitated supplies; their orders were cryptic and showed non-application of mind. Consequence: impugned orders set aside and matter remanded to appellate and refund sanctioning authorities for fresh decision. - HC
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