Effective service requirement: officers must explore alternative service modes beyond the GST portal and afford personal hearing; non-compliance voids...
Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
A writ petition challenging GST search, seizure and adjudicatory action was declined because the petitioners had an efficacious statutory appeal and no exceptional ground for writ interference. The Court also found no prima facie merit in the objections to officer competence or adjudication by the officer concerned, noting the notification assigning powers to Central Tax Officers and the absence of any substantive merits challenge. A vires challenge to the impugned circulars was not entertained because such a challenge must be raised at the earliest and requires a strong prima facie case, which was not shown. The petitioners were left to pursue the appellate remedy, without any final adjudication on merits.
A writ petition challenging GST search, seizure and adjudicatory action was declined because the petitioners had an efficacious statutory appeal and no exceptional ground for writ interference. The Court also found no prima facie merit in the objections to officer competence or adjudication by the officer concerned, noting the notification assigning powers to Central Tax Officers and the absence of any substantive merits challenge. A vires challenge to the impugned circulars was not entertained because such a challenge must be raised at the earliest and requires a strong prima facie case, which was not shown. The petitioners were left to pursue the appellate remedy, without any final adjudication on merits.
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