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...
High Court considered condonation of delay where an adjudication order was allegedly served only by uploading on the GST portal; limitation does not commence if service was not properly effected. The HC observed the grounds for condonation were not previously presented to the Appellate Authority but granted the petitioner an opportunity to reapply within three weeks with supporting explanations and documents. The Appellate Authority must reconsider the condonation application in light of the Division Bench precedent in M/s Ram Kumar Sinhal and related judgments; if satisfied the delay is excusable or service was ineffective, it shall hear the appeal and the impugned appellate order will be set aside.
High Court considered condonation of delay where an adjudication order was allegedly served only by uploading on the GST portal; limitation does not commence if service was not properly effected. The HC observed the grounds for condonation were not previously presented to the Appellate Authority but granted the petitioner an opportunity to reapply within three weeks with supporting explanations and documents. The Appellate Authority must reconsider the condonation application in light of the Division Bench precedent in M/s Ram Kumar Sinhal and related judgments; if satisfied the delay is excusable or service was ineffective, it shall hear the appeal and the impugned appellate order will be set aside.
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