Force majeure causation in GST limitation: proximate cause and mandatory council recommendation govern valid time limit extensions. Section 168A empowers executive modification of GST limitation periods but operates as delegated legislation subject to strict construction: valid ... Summary
Force majeure causation in GST limitation: proximate cause and mandatory council recommendation govern valid time limit extensions.
Section 168A empowers executive modification of GST limitation periods but operates as delegated legislation subject to strict construction: valid exercise requires (i) a qualifying force majeure event, (ii) inability to complete prescribed actions, and (iii) proximate causation by that event; GST Council recommendation is a mandatory precondition and GIC substitution or post-facto ratification does not cure statutory defect.
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