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...
Writ jurisdiction under Article 226 was held unsuitable for quashing a pending CGST criminal prosecution where the complaint raised several disputed factual issues requiring trial. The Court treated the complaint as the foundation of the prosecution and declined to undertake any fact-finding inquiry or interfere with triable matters. It also held that Suncraft Energy (P) Ltd. was inapplicable because that decision concerned revenue action, not a pending criminal prosecution. The writ petition was dismissed, with liberty to the petitioner to raise all factual and jurisdictional objections before the jurisdictional criminal court during trial.
Writ jurisdiction under Article 226 was held unsuitable for quashing a pending CGST criminal prosecution where the complaint raised several disputed factual issues requiring trial. The Court treated the complaint as the foundation of the prosecution and declined to undertake any fact-finding inquiry or interfere with triable matters. It also held that Suncraft Energy (P) Ltd. was inapplicable because that decision concerned revenue action, not a pending criminal prosecution. The writ petition was dismissed, with liberty to the petitioner to raise all factual and jurisdictional objections before the jurisdictional criminal court during trial.
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