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...
Departmental undertaking that originals of seized documents missing from custody will not be relied upon resolves the specific grievance; adjudication may proceed for the listed tax periods on other available materials while ensuring the assessee is afforded the statutory right to file replies and be heard under the TGST Act. The decision rests on the department's representation and the procedural requirement of fair opportunity of hearing; there is no adjudication on the substantive validity or content of the seized materials whose originals are absent.
Departmental undertaking that originals of seized documents missing from custody will not be relied upon resolves the specific grievance; adjudication may proceed for the listed tax periods on other available materials while ensuring the assessee is afforded the statutory right to file replies and be heard under the TGST Act. The decision rests on the department's representation and the procedural requirement of fair opportunity of hearing; there is no adjudication on the substantive validity or content of the seized materials whose originals are absent.
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