Effective service requirement: officers must explore alternative service modes beyond the GST portal and afford personal hearing; non-compliance voids...
Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Assessee was required to file the statutory auditor report under the proviso applicable from the specified cut-off date for the assessment year 2022-23; mere submission of a CA certificate did not satisfy the audit-report requirement, and the assessee could not treat the proviso as retrospectively inapplicable for its convenience. Because the auditor report was not filed as prescribed, penalty for non-compliance was held justified and the appeal dismissed.
Assessee was required to file the statutory auditor report under the proviso applicable from the specified cut-off date for the assessment year 2022-23; mere submission of a CA certificate did not satisfy the audit-report requirement, and the assessee could not treat the proviso as retrospectively inapplicable for its convenience. Because the auditor report was not filed as prescribed, penalty for non-compliance was held justified and the appeal dismissed.
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