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...
Order sets aside impugned adjudication and remits the matter for fresh merit determination, directing the respondent to take into account the State Authority's order for the same tax period. Petitioner must particularize each pre GST transaction alleged to have been subject to Service Tax/VAT, substantiate claims with annexures (mere filing inadequate), and file a proper reply treating the prior Order in Original as an addendum to the Show Cause Notice within thirty days. A personal hearing is to be afforded before any final order is passed.
Order sets aside impugned adjudication and remits the matter for fresh merit determination, directing the respondent to take into account the State Authority's order for the same tax period. Petitioner must particularize each pre GST transaction alleged to have been subject to Service Tax/VAT, substantiate claims with annexures (mere filing inadequate), and file a proper reply treating the prior Order in Original as an addendum to the Show Cause Notice within thirty days. A personal hearing is to be afforded before any final order is passed.
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