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...
Denial of input tax credit was grounded solely on the supplier's non-filing of Form GSTR-3B; when the supplier subsequently filed returns for the disputed months the original demands were rightly dropped for those months but remained for the month still unfiled. The appellate authority relied on additional grounds not pleaded in the notice to show cause, contrary to the principle that adjudication must remain within the confines of the notice. Because adjudication on extraneous grounds breaches the obligation to afford a hearing on those grounds, the appellate order was set aside and the matter remitted for fresh decision after affording an opportunity to be heard.
Denial of input tax credit was grounded solely on the supplier's non-filing of Form GSTR-3B; when the supplier subsequently filed returns for the disputed months the original demands were rightly dropped for those months but remained for the month still unfiled. The appellate authority relied on additional grounds not pleaded in the notice to show cause, contrary to the principle that adjudication must remain within the confines of the notice. Because adjudication on extraneous grounds breaches the obligation to afford a hearing on those grounds, the appellate order was set aside and the matter remitted for fresh decision after affording an opportunity to be heard.
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