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...
Entitlement to reimbursement of differential GST under a government contract was not decided on merits. The Court accepted the respondents' position that a mere assertion of tax payment was insufficient and that supporting documents evidencing actual payment or deposit of GST were required. It directed the petitioner to furnish proof of GST payment and ordered the respondents to examine the reimbursement claim and pass a reasoned decision in accordance with law within the stipulated time. No final adjudication was made on the substantive right to reimbursement.
Entitlement to reimbursement of differential GST under a government contract was not decided on merits. The Court accepted the respondents' position that a mere assertion of tax payment was insufficient and that supporting documents evidencing actual payment or deposit of GST were required. It directed the petitioner to furnish proof of GST payment and ordered the respondents to examine the reimbursement claim and pass a reasoned decision in accordance with law within the stipulated time. No final adjudication was made on the substantive right to reimbursement.
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