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...
Pigmy agents engaged by a bank were treated as employees because the relationship was marked by pervasive control, supervision and disciplinary oversight, with commission functioning in substance as wages. Their services rendered in the course of employment fell within Schedule III read with section 7(2)(a) of the GST law and were therefore neither a supply of goods nor a supply of services. The attempt to classify them as business facilitators liable under reverse charge was rejected, and the show cause notices were quashed for proceeding on an erroneous jurisdictional basis. The challenge to the limitation-extension notifications was left open.
Pigmy agents engaged by a bank were treated as employees because the relationship was marked by pervasive control, supervision and disciplinary oversight, with commission functioning in substance as wages. Their services rendered in the course of employment fell within Schedule III read with section 7(2)(a) of the GST law and were therefore neither a supply of goods nor a supply of services. The attempt to classify them as business facilitators liable under reverse charge was rejected, and the show cause notices were quashed for proceeding on an erroneous jurisdictional basis. The challenge to the limitation-extension notifications was left open.
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