Marketing support and subcontracted client contracts: no agency permanent establishment under Article 5 DTAA; arm's-length pricing bars profit attribu...
Remittal for fresh adjudication was ordered due to a dispute over excess input tax credit reconciliation between GSTR-2A and GSTR-2B, with the appellate proceedings returned to the adjudicating authority for fresh consideration; the petitioner must, within 30 days of receipt, deposit an additional 40% of the disputed tax in addition to the earlier 10% to obtain interim relief. The petitioner must file a detailed reply to the GST DRC-01 show cause notice treating the impugned order as an addendum and produce supporting documents; bank attachment will be lifted only upon the directed deposit and absence of other arrears, failing which recovery proceedings may resume as if the petition were dismissed.
Remittal for fresh adjudication was ordered due to a dispute over excess input tax credit reconciliation between GSTR-2A and GSTR-2B, with the appellate proceedings returned to the adjudicating authority for fresh consideration; the petitioner must, within 30 days of receipt, deposit an additional 40% of the disputed tax in addition to the earlier 10% to obtain interim relief. The petitioner must file a detailed reply to the GST DRC-01 show cause notice treating the impugned order as an addendum and produce supporting documents; bank attachment will be lifted only upon the directed deposit and absence of other arrears, failing which recovery proceedings may resume as if the petition were dismissed.
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