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...
Limitation for IGST refund claims by specified international organisations was reckoned from 01.08.2019, because Circular No. 23/2019-Customs first clarified that Customs authorities were the competent refund forum. On that basis, the limitation under Notification No. 20/2018-Central Tax was not exhausted when the claims were filed, and the COVID-19 extension of limitation also applied. The claims were therefore treated as within time and not liable to rejection as time-barred.
Limitation for IGST refund claims by specified international organisations was reckoned from 01.08.2019, because Circular No. 23/2019-Customs first clarified that Customs authorities were the competent refund forum. On that basis, the limitation under Notification No. 20/2018-Central Tax was not exhausted when the claims were filed, and the COVID-19 extension of limitation also applied. The claims were therefore treated as within time and not liable to rejection as time-barred.
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