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...
An assessment order must bear a signature, and an unsigned order is invalid. The High Court also recognised practical difficulties in accessing orders uploaded on the portal and held that delay in invoking writ jurisdiction can be overlooked where the assessment suffers from a patent irregularity, while balancing taxpayer hardship against revenue protection. The unsigned assessment orders were set aside and the matter was remanded for fresh assessment after hearing, subject to deposit of 20% of the disputed tax, adjustment of amounts already paid or recovered, and exclusion of the writ period for limitation.
An assessment order must bear a signature, and an unsigned order is invalid. The High Court also recognised practical difficulties in accessing orders uploaded on the portal and held that delay in invoking writ jurisdiction can be overlooked where the assessment suffers from a patent irregularity, while balancing taxpayer hardship against revenue protection. The unsigned assessment orders were set aside and the matter was remanded for fresh assessment after hearing, subject to deposit of 20% of the disputed tax, adjustment of amounts already paid or recovered, and exclusion of the writ period for limitation.
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