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...
Clubbing of tax periods in a single Section 74 show cause notice is impermissible because the CGST statutory scheme treats each financial year as a distinct tax period with separate limitation and procedural rights; aggregating years conflates distinct limitation dates and denies year wise rights, and allegations of fraudulent input tax credit do not authorise consolidation. Applying that principle, the court quashed the consolidated notice covering multiple financial years but permitted respondents liberty to reissue notices strictly year wise in accordance with the statutory scheme and to revive proceedings if higher forum decisions permit.
Clubbing of tax periods in a single Section 74 show cause notice is impermissible because the CGST statutory scheme treats each financial year as a distinct tax period with separate limitation and procedural rights; aggregating years conflates distinct limitation dates and denies year wise rights, and allegations of fraudulent input tax credit do not authorise consolidation. Applying that principle, the court quashed the consolidated notice covering multiple financial years but permitted respondents liberty to reissue notices strictly year wise in accordance with the statutory scheme and to revive proceedings if higher forum decisions permit.
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