Income Disclosure Scheme immunity and search-material requirements barred further share-transaction additions in unabated assessments under section 15...
Toy balloon tariff classification: functional heading prevails over residual rubber and festive article headings, supporting penalties for deliberate ...
Customs valuation using comparable contemporaneous imports can displace declared value, while missing speaking orders require pursuit before competent...
Foreign customs declarations and importer admissions established undervaluation, supporting sequential value redetermination, differential duty, and m...
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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