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...
Remand required for fresh adjudication of tax demands arising from admitted reverse charge mechanism liability and disputed input tax credit (ITC) reversal; the commentary stresses that although Section 42 (ITC reversal) was later deleted by Finance Act, 2022, the effect of that repeal on past liabilities and entitlement to retrospective benefit must be considered on merits. Petitioner had sought time but failed to challenge an excess ITC demand, which was confirmed; bank attachment is ordered lifted conditionally upon deposit of the tax liability and no other arrears, with liberty to recover if stipulated compliance fails.
Remand required for fresh adjudication of tax demands arising from admitted reverse charge mechanism liability and disputed input tax credit (ITC) reversal; the commentary stresses that although Section 42 (ITC reversal) was later deleted by Finance Act, 2022, the effect of that repeal on past liabilities and entitlement to retrospective benefit must be considered on merits. Petitioner had sought time but failed to challenge an excess ITC demand, which was confirmed; bank attachment is ordered lifted conditionally upon deposit of the tax liability and no other arrears, with liberty to recover if stipulated compliance fails.
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