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...
Retrospective insertion of Section 16(5) of the CGST Act saved input tax credit claims for the specified financial years when returns were filed up to 30.11.2021, notwithstanding the limitation in Section 16(4). The High Court followed its earlier common order and quashed the impugned reversal to the extent it denied ITC solely on limitation, making that coercive action unsustainable on that ground alone. The Department's liberty was preserved to proceed in accordance with law on separate issues such as discrepancy, wrong availment, excess claim, or fake ITC, if any.
Retrospective insertion of Section 16(5) of the CGST Act saved input tax credit claims for the specified financial years when returns were filed up to 30.11.2021, notwithstanding the limitation in Section 16(4). The High Court followed its earlier common order and quashed the impugned reversal to the extent it denied ITC solely on limitation, making that coercive action unsustainable on that ground alone. The Department's liberty was preserved to proceed in accordance with law on separate issues such as discrepancy, wrong availment, excess claim, or fake ITC, if any.
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