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...
Issuing a composite show-cause notice covering multiple tax periods under the CGST/KGST regime was treated as a jurisdictional defect, following the view that clubbing separate periods in one notice is illegal and impermissible. The impugned notice and the adjudication order founded on it were set aside. Liberty was reserved to the revenue to initiate fresh proceedings through separate show-cause notices for each tax period, and all other contentions were left open.
Issuing a composite show-cause notice covering multiple tax periods under the CGST/KGST regime was treated as a jurisdictional defect, following the view that clubbing separate periods in one notice is illegal and impermissible. The impugned notice and the adjudication order founded on it were set aside. Liberty was reserved to the revenue to initiate fresh proceedings through separate show-cause notices for each tax period, and all other contentions were left open.
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