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...
An assessment order issued under the GST regime without a Document Identification Number was treated as non-est and unsustainable, following the principle that a DIN is mandatory for validity. The Court also held that a writ petition challenging the original assessment remained maintainable even though the statutory appeal had been dismissed as time-barred, since the challenge was directed to the invalidity of the foundational order. The assessment order was set aside and the matter remanded to the Assessing Officer for fresh consideration in accordance with law, with exclusion of the intervening period for limitation purposes.
An assessment order issued under the GST regime without a Document Identification Number was treated as non-est and unsustainable, following the principle that a DIN is mandatory for validity. The Court also held that a writ petition challenging the original assessment remained maintainable even though the statutory appeal had been dismissed as time-barred, since the challenge was directed to the invalidity of the foundational order. The assessment order was set aside and the matter remanded to the Assessing Officer for fresh consideration in accordance with law, with exclusion of the intervening period for limitation purposes.
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