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...
The High Court found no breach of natural justice because the impugned order showed that a personal hearing had been given. It also relied on factual findings that no business activity existed at the declared premises and that fake invoices were used through the petitioner's credentials to avail input tax credit. As the dispute turned on contested facts, the Court declined to examine the merits in writ jurisdiction and directed the petitioner to pursue the statutory appellate remedy, with liberty to file an appeal within the time granted and have it heard on merits.
The High Court found no breach of natural justice because the impugned order showed that a personal hearing had been given. It also relied on factual findings that no business activity existed at the declared premises and that fake invoices were used through the petitioner's credentials to avail input tax credit. As the dispute turned on contested facts, the Court declined to examine the merits in writ jurisdiction and directed the petitioner to pursue the statutory appellate remedy, with liberty to file an appeal within the time granted and have it heard on merits.
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