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...
Writ challenges to show-cause and pre-intimation notices blocking input tax credit were held premature where the disputes turned on individual facts and the CGST Act and Rules provided a complete code. The Court declined to examine the merits of the proposed ITC action or the constitutional validity of Section 16(2)(c) at this stage, finding that such issues required case-specific adjudication after replies and objections were considered. Petitioners were permitted to respond to the notices, and the statutory authorities were directed to decide the matters in accordance with law, while keeping all contentions open.
Writ challenges to show-cause and pre-intimation notices blocking input tax credit were held premature where the disputes turned on individual facts and the CGST Act and Rules provided a complete code. The Court declined to examine the merits of the proposed ITC action or the constitutional validity of Section 16(2)(c) at this stage, finding that such issues required case-specific adjudication after replies and objections were considered. Petitioners were permitted to respond to the notices, and the statutory authorities were directed to decide the matters in accordance with law, while keeping all contentions open.
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