2023 (12) TMI 990

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....te. For the Respondent : None   1. Inter alia contends that the petitioner has entered into Secondment & Cost Reimbursement Agreement dated 31.03.2019 (Annexure P-2) with Mitsubishi Electric Corporation, Japan, the parent company wherein certain employees have been seconded for service in India. While referring to the salary component it is pointed out that certain amounts are paid in Indi....

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....(Annexure P-6). Having received the same, the respondent-authorities closed the proceedings without issuance of the show cause notice as per the provisions of Section 73(6) of the Central Goods Service Tax Act, 2017 (for short, the 'Act') leaving its right open to investigate for remaining tax duties and liabilities and other issues for the similar period. 3. Thereafter, vide communication dated ....

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.... covered and secondly a closure letter had already been issued. Inspite of that, notice dated 29.09.2023 (Annexure P-1) was issued under Section 73(8) of the Act that if the amount be paid within 30 days no penalty will be payable in respect of the such tax and interest. 3. It is contended that a similar issue has also come up for consideration before the High Court of Karnataka in WP-23915-2023 ....