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...
Section 66 contemplates a special audit only where the case is complex and the competent officer records the requisite opinion in the interest of revenue; once that audit is completed and the report is filed, a supplementary or additional report cannot be directed because it would reopen a concluded exercise. The Court also noted that the audit had already served its purpose for the provisional attachment proceedings, so a further Chartered Accountant's report would serve no purpose. The writ challenge to provisional attachment also failed because the bank accounts had already been defreezed and the attachments lifted, rendering the petition infructuous.
Section 66 contemplates a special audit only where the case is complex and the competent officer records the requisite opinion in the interest of revenue; once that audit is completed and the report is filed, a supplementary or additional report cannot be directed because it would reopen a concluded exercise. The Court also noted that the audit had already served its purpose for the provisional attachment proceedings, so a further Chartered Accountant's report would serve no purpose. The writ challenge to provisional attachment also failed because the bank accounts had already been defreezed and the attachments lifted, rendering the petition infructuous.
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