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...
Belated statutory appeals under GST may still be entertained conditionally where the court exercises discretion despite expiry of limitation. The text explains that the writ challenge was not accepted on merits because the petitioner had not used the statutory reduced-penalty amnesty and had approached the court after the appeal period had lapsed. Even so, the court granted liberty to file an appeal within the time fixed, subject to pre-deposit of 25% of the disputed tax. On compliance, the appellate authority was directed to hear the appeal on merits, adjust any amount already recovered toward the pre-deposit, and lift bank attachment if applicable.
Belated statutory appeals under GST may still be entertained conditionally where the court exercises discretion despite expiry of limitation. The text explains that the writ challenge was not accepted on merits because the petitioner had not used the statutory reduced-penalty amnesty and had approached the court after the appeal period had lapsed. Even so, the court granted liberty to file an appeal within the time fixed, subject to pre-deposit of 25% of the disputed tax. On compliance, the appellate authority was directed to hear the appeal on merits, adjust any amount already recovered toward the pre-deposit, and lift bank attachment if applicable.
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