Clean slate principle extinguishes uncrystallised operational claims and bars continuation of pending recovery and arbitral proceedings after plan app...
Works contract classification governs composite layout-development contracts where VAT-paid goods are transferred alongside construction and infrastru...
Specified income tax exemption for pollution control body remains conditional on non-commercial activity, unchanged income character, and return filin...
Jurisdictional facts in certificate-of-origin discrepancies can support customs show-cause proceedings, leaving factual explanations for departmental ...
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.
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