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...
Processing of TDS statements under section 200A could not, for periods before 01.06.2015, be used to compute and levy late fee under section 234E because the enabling provision came into force only from that date. For quarterly TDS returns relating to FY 2014-15, the levy raised in the intimation under section 200A was therefore without authority and invalid. The Tribunal followed jurisdictional High Court and co-ordinate bench rulings and directed deletion of the late fee charged in the intimation.
Processing of TDS statements under section 200A could not, for periods before 01.06.2015, be used to compute and levy late fee under section 234E because the enabling provision came into force only from that date. For quarterly TDS returns relating to FY 2014-15, the levy raised in the intimation under section 200A was therefore without authority and invalid. The Tribunal followed jurisdictional High Court and co-ordinate bench rulings and directed deletion of the late fee charged in the intimation.
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