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...
Where registration had already been cancelled, adjudication could continue only on physical service of the show cause notice because the taxpayer could not be expected to access the Common Portal; service merely by electronic upload was therefore inadequate. The absence of physical notice caused a substantial breach of natural justice and denied an effective opportunity to file objections and be heard. The HC accordingly set aside the adjudication order and remitted the matter for fresh adjudication after physical service of notice, supply of relied-upon documents, and grant of due hearing.
Where registration had already been cancelled, adjudication could continue only on physical service of the show cause notice because the taxpayer could not be expected to access the Common Portal; service merely by electronic upload was therefore inadequate. The absence of physical notice caused a substantial breach of natural justice and denied an effective opportunity to file objections and be heard. The HC accordingly set aside the adjudication order and remitted the matter for fresh adjudication after physical service of notice, supply of relied-upon documents, and grant of due hearing.
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