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...
Raw, unprocessed Psyllium seeds (Isabgol) procured directly from farmers through APMC auctions, and supplied without drying, freezing, crushing or other processing, were treated as fresh goods under heading 1211. The Authority relied on tariff and HSN notes to hold that goods retained their natural character up to supply and did not fall within entries for frozen or dried goods. It also held that the specific exemption for fresh or chilled goods under Entry 87 of Notification No. 10/2025-Central Tax (Rate) prevailed over the more general exemption for goods of seed quality. Accordingly, the supply was held exempt from GST.
Raw, unprocessed Psyllium seeds (Isabgol) procured directly from farmers through APMC auctions, and supplied without drying, freezing, crushing or other processing, were treated as fresh goods under heading 1211. The Authority relied on tariff and HSN notes to hold that goods retained their natural character up to supply and did not fall within entries for frozen or dried goods. It also held that the specific exemption for fresh or chilled goods under Entry 87 of Notification No. 10/2025-Central Tax (Rate) prevailed over the more general exemption for goods of seed quality. Accordingly, the supply was held exempt from GST.
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