Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
The High Court declined to examine the merits of the challenge to the show cause notice and ex parte adjudication order, holding that the petitioner had already attempted to pursue the statutory appellate remedy and had made the required pre-deposit. As the appeal could not be uploaded on the portal because of a technical glitch, the Court directed the petitioner to file the appeal afresh under the proviso to Rule 108 of the CGST Rules, 2017, permitted all grounds to be raised before the appellate authority, and condoned the delay in filing. The writ petition was disposed of in favour of pursuing the statutory remedy.
The High Court declined to examine the merits of the challenge to the show cause notice and ex parte adjudication order, holding that the petitioner had already attempted to pursue the statutory appellate remedy and had made the required pre-deposit. As the appeal could not be uploaded on the portal because of a technical glitch, the Court directed the petitioner to file the appeal afresh under the proviso to Rule 108 of the CGST Rules, 2017, permitted all grounds to be raised before the appellate authority, and condoned the delay in filing. The writ petition was disposed of in favour of pursuing the statutory remedy.
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TaxTMI 
TaxTMI 
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