Co-operative deduction eligibility excludes refund and commercial-bank interest, while qualifying co-operative investments require entity-wise verific...
Enhanced tax rate on surrendered unexplained income applies prospectively, while cash-deposit telescoping requires verification of available surrender...
Customs Broker licence proceedings require accurate procedural facts before delay or natural-justice findings can justify setting aside regulatory act...
Provisional assessment finalisation must precede export duty recovery, while redemption fine fails for goods already exported and unavailable for conf...
A consolidated show cause notice covering multiple financial years under Section 74 of the CGST Act was held invalid because limitation and determination are linked year-wise to each financial year's annual return, so each period carries its own independent limitation timeline. The Court found that clubbing distinct tax periods in one notice can prejudice year-specific defences and is not justified unless there is a composite, interlinked fraudulent scheme spanning several years forming an indivisible basis for proceedings; no such allegation was made here. The consolidated notices and consequential adjudication orders were quashed, with liberty to issue fresh year-wise notices if otherwise permissible in law.
A consolidated show cause notice covering multiple financial years under Section 74 of the CGST Act was held invalid because limitation and determination are linked year-wise to each financial year's annual return, so each period carries its own independent limitation timeline. The Court found that clubbing distinct tax periods in one notice can prejudice year-specific defences and is not justified unless there is a composite, interlinked fraudulent scheme spanning several years forming an indivisible basis for proceedings; no such allegation was made here. The consolidated notices and consequential adjudication orders were quashed, with liberty to issue fresh year-wise notices if otherwise permissible in law.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4814 
Join Channel 
