The Supreme Court ruled that directions to modify tax software had no nexus with the individual dispute. Relief granted to the assessee under Section 205 was left undisturbed.
The Supreme Court dismissed the SLP as withdrawn after permitting the taxpayer to pursue a statutory appeal. The ruling reinforces that GST disputes should follow the appeal route under Section 107.
The issue was whether commissions from foreign universities attract GST as intermediary services. The court held that principal-to-principal consultancy services qualify as export, entitling refund.
The SC rejected the State’s challenge citing an unexplained 676-day delay and found no reason to interfere with the High Court’s refund order. The High Court’s direction to process the original refund claim remained effective.
Following the High Court’s ruling on limitation, the Supreme Court dismissed the SLP as withdrawn. The decision leaves intact the finding that delayed GST appeals are not maintainable.
The courts held that interest and penalties on IGST imports cannot be imposed without explicit legal provision. Amendments granting such power apply only prospectively.
The Supreme Court declined to interfere where courts below found no permanent establishment in India due to offshore execution of contracts. The ruling confirms that profit attribution fails without a PE.
The Supreme Court rejected the challenge to an SFIO investigation order due to massive delay and lack of merit. It upheld the High Court’s finding that statutory conditions under Section 212 were not properly satisfied.
SC dismissed the Revenue’s delayed appeal, letting stand the ruling that only the recognised PGP course qualifies for service tax exemption. Other executive and specialised programmes remained taxable.
The Supreme Court refused to interfere with the High Court’s decision dismissing a revision filed after nearly seven years. It affirmed that unexplained and excessive delay defeats relief under Section 264.
