Effective service requirement: officers must explore alternative service modes beyond the GST portal and afford personal hearing; non-compliance voids...
Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
The court addressed whether parallel proceedings under Sections 73/74 and Section 122 (penalty) create impermissible overlap and whether the show-cause notice could proceed pending resolution of a state appeal; it declined to decide the overlap on merits but ordered the state Appellate Authority to conclude the pending appeal within a limited period - outcome: appeal to be disposed within three weeks and the Central Authorities may proceed with the show-cause notice only after that conclusion. The petitioner may thereafter file a reply raising the overlap and reliance on the CBIC circular; remedies preserved. - HC
The court addressed whether parallel proceedings under Sections 73/74 and Section 122 (penalty) create impermissible overlap and whether the show-cause notice could proceed pending resolution of a state appeal; it declined to decide the overlap on merits but ordered the state Appellate Authority to conclude the pending appeal within a limited period - outcome: appeal to be disposed within three weeks and the Central Authorities may proceed with the show-cause notice only after that conclusion. The petitioner may thereafter file a reply raising the overlap and reliance on the CBIC circular; remedies preserved. - HC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4827 
Join Channel 
