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...
Refund of unutilized input tax credit under the Central GST framework was contested due to failure to satisfy export of services conditions under IGST; the agency/intermediary characterisation of the petitioners role with respect to the parent entity required reassessment. The appellate authority is directed to re-examine contractual clauses, the applicability of relevant circulars and the Sundyne Pumps precedent, and record specific findings. The impugned administrative order is quashed and the matter is remitted for de novo consideration and a fresh decision in accordance with law.
Refund of unutilized input tax credit under the Central GST framework was contested due to failure to satisfy export of services conditions under IGST; the agency/intermediary characterisation of the petitioners role with respect to the parent entity required reassessment. The appellate authority is directed to re-examine contractual clauses, the applicability of relevant circulars and the Sundyne Pumps precedent, and record specific findings. The impugned administrative order is quashed and the matter is remitted for de novo consideration and a fresh decision in accordance with law.
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