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...
The High Court noted that the appellate authority could not condone delay beyond the statutory period and upheld the rejection of the appeal on limitation. It nevertheless accepted that the taxpayer had bona fide reasons for not filing returns and that continued cancellation of GST registration would cause adverse civil consequences without benefiting revenue if compliance could still be secured. Exercising writ jurisdiction, the Court quashed the cancellation and appellate orders, directed restoration of registration, and allowed time to complete the remaining statutory obligations.
The High Court noted that the appellate authority could not condone delay beyond the statutory period and upheld the rejection of the appeal on limitation. It nevertheless accepted that the taxpayer had bona fide reasons for not filing returns and that continued cancellation of GST registration would cause adverse civil consequences without benefiting revenue if compliance could still be secured. Exercising writ jurisdiction, the Court quashed the cancellation and appellate orders, directed restoration of registration, and allowed time to complete the remaining statutory obligations.
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