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...
Petitioner proved payment of GST by documentary verification from the tax authority and submitted a supplementary agreement; respondents' refusal to reimburse on account of a final bill and a no-claim certificate was found legally unsustainable. The supplementary agreement, though not executed by the respondent, was presented with due signature and cannot be imputed as petitioner's fault, and parallel administrative acceptances of similar claims were noted. Operatively, the petitioner is entitled to GST neutralisation and the department is directed to accept the claim and reimburse the GST amount as due.
Petitioner proved payment of GST by documentary verification from the tax authority and submitted a supplementary agreement; respondents' refusal to reimburse on account of a final bill and a no-claim certificate was found legally unsustainable. The supplementary agreement, though not executed by the respondent, was presented with due signature and cannot be imputed as petitioner's fault, and parallel administrative acceptances of similar claims were noted. Operatively, the petitioner is entitled to GST neutralisation and the department is directed to accept the claim and reimburse the GST amount as due.
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