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...
Delayed filing of the annual return in GSTR-9 attracted a specific late fee under the GST enactments, but the Court applied its earlier ruling to hold that general penalty under Section 125 could not be imposed for the same default. It further held that the late fee could not be demanded beyond the permissible limit recognised in that precedent, and the demand in excess of the limit under the CGST and SGST enactments was unsustainable. The impugned order was therefore set aside to that extent, while the petitioner was directed to pay the admitted tax liability within the time granted.
Delayed filing of the annual return in GSTR-9 attracted a specific late fee under the GST enactments, but the Court applied its earlier ruling to hold that general penalty under Section 125 could not be imposed for the same default. It further held that the late fee could not be demanded beyond the permissible limit recognised in that precedent, and the demand in excess of the limit under the CGST and SGST enactments was unsustainable. The impugned order was therefore set aside to that extent, while the petitioner was directed to pay the admitted tax liability within the time granted.
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TaxTMI 
TaxTMI 
of 4918 
