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...
A challenge to a show cause notice under the GST framework raises disputed factual issues best resolved in adjudication; accordingly, preadjudication interference is declined. The petitioner need not be compelled to deposit proposed amounts before adjudication. Statements of recipients recorded in investigation may be relied upon by revenue, but the petitioner is entitled to crossexamine those witnesses before any adverse inference is drawn; that right will be afforded. Documentary records relied on by revenue may be challenged for reliability and the petitioner has the right to rebut inferences drawn from such documents. Facts and law must be determined during adjudication.
A challenge to a show cause notice under the GST framework raises disputed factual issues best resolved in adjudication; accordingly, preadjudication interference is declined. The petitioner need not be compelled to deposit proposed amounts before adjudication. Statements of recipients recorded in investigation may be relied upon by revenue, but the petitioner is entitled to crossexamine those witnesses before any adverse inference is drawn; that right will be afforded. Documentary records relied on by revenue may be challenged for reliability and the petitioner has the right to rebut inferences drawn from such documents. Facts and law must be determined during adjudication.
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