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...
Abeyance of limitation applies where a rectification application under the GST statute was pending; the time spent pursuing rectification is excluded and the appeal is maintainable despite delay, the Court applying the principle of bona fide pursuit before a wrong forum and directing the appellate authority to decide on merits. Because the petitioner deposited 10% in the leading matter and 25% in the connected matter, the appeals are to be treated as not barred by delay, and the appellate authority must decide them on merits within two months. Writ petitions disposed accordingly.
Abeyance of limitation applies where a rectification application under the GST statute was pending; the time spent pursuing rectification is excluded and the appeal is maintainable despite delay, the Court applying the principle of bona fide pursuit before a wrong forum and directing the appellate authority to decide on merits. Because the petitioner deposited 10% in the leading matter and 25% in the connected matter, the appeals are to be treated as not barred by delay, and the appellate authority must decide them on merits within two months. Writ petitions disposed accordingly.
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