Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
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Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Sections 73 and 74 of the CGST Act do not bar a common or consolidated show cause notice for more than one tax period or financial year. The Court held that the references to "any period" and the limitation provisions do not confine notice issuance to a single financial year, while each component of a consolidated notice must still independently satisfy the applicable limitation test. It also rejected the objection based on pecuniary jurisdiction of the proper officer. Where Orders-in-Original were challenged, the Court restored the statutory position and granted time to file appeals, with limitation objections not to be raised if appeals were filed within the period allowed.
Sections 73 and 74 of the CGST Act do not bar a common or consolidated show cause notice for more than one tax period or financial year. The Court held that the references to "any period" and the limitation provisions do not confine notice issuance to a single financial year, while each component of a consolidated notice must still independently satisfy the applicable limitation test. It also rejected the objection based on pecuniary jurisdiction of the proper officer. Where Orders-in-Original were challenged, the Court restored the statutory position and granted time to file appeals, with limitation objections not to be raised if appeals were filed within the period allowed.
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