Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
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The principal issue was whether the taxpayer's refund claim for accumulated input tax credit, filed in Form GST RFD-01 after portal-size constraints prevented uploading supporting shipping bills and after earlier rejection and re-credit to the electronic credit ledger, was maintainable despite the portal error and the issuance of a deficiency memo under Rule 89(5) alleging non-debit of credit. The court found the claim substantively supported by compliance with Circular No.125/44/2019-GST and related submissions, and directed respondents to verify the enclosed documents and process the refund claim accordingly, allowing the petition. - HC
The principal issue was whether the taxpayer's refund claim for accumulated input tax credit, filed in Form GST RFD-01 after portal-size constraints prevented uploading supporting shipping bills and after earlier rejection and re-credit to the electronic credit ledger, was maintainable despite the portal error and the issuance of a deficiency memo under Rule 89(5) alleging non-debit of credit. The court found the claim substantively supported by compliance with Circular No.125/44/2019-GST and related submissions, and directed respondents to verify the enclosed documents and process the refund claim accordingly, allowing the petition. - HC
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