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...
Maintainability of a writ under Article 226 is limited where an alternative statutory appeal exists and the impugned orders arise from rectification proceedings under Section 161 of the GST Act; the court found no pleaded illegality and noted the petitioner received personal hearing before rectification orders were passed, so disputed questions of fact and the availability of an appeal precluded exercise of extraordinary writ jurisdiction. Outcome: writ petition dismissed and petitioner left to pursue the statutory appellate remedy.
Maintainability of a writ under Article 226 is limited where an alternative statutory appeal exists and the impugned orders arise from rectification proceedings under Section 161 of the GST Act; the court found no pleaded illegality and noted the petitioner received personal hearing before rectification orders were passed, so disputed questions of fact and the availability of an appeal precluded exercise of extraordinary writ jurisdiction. Outcome: writ petition dismissed and petitioner left to pursue the statutory appellate remedy.
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