Captive power transfer pricing and non-resident export commission rules support deletion of adjustments and withholding disallowance in discussed proc...
Cooperative society deposits, member-interest TDS exemption and credit-facility deduction claims require verification through records and supporting e...
Customs jurisdiction over EPCG condition breaches survives export-obligation discharge certificates, requiring alleged fraud and misdeclaration to be ...
In GST proceedings, invocation of the extended period under Section 74 depends on jurisdictional or foundational facts and a prima facie view, based on available material, that non-payment, short payment, wrongful input tax credit, fraud, wilful misstatement or suppression exists. The notice should ordinarily disclose the basis for alleging the mental element, but prior communication of those grounds through scrutiny, audit, inspection or pre-notice intimation can satisfy the requirement, so a detailed notice is not invalid merely because it repeats earlier allegations. Notices were upheld where the basis had already been disclosed, while an inadequately particularised order was remitted for fresh consideration under Section 73, with possible recourse to Section 74 if information remained unprovided.
In GST proceedings, invocation of the extended period under Section 74 depends on jurisdictional or foundational facts and a prima facie view, based on available material, that non-payment, short payment, wrongful input tax credit, fraud, wilful misstatement or suppression exists. The notice should ordinarily disclose the basis for alleging the mental element, but prior communication of those grounds through scrutiny, audit, inspection or pre-notice intimation can satisfy the requirement, so a detailed notice is not invalid merely because it repeats earlier allegations. Notices were upheld where the basis had already been disclosed, while an inadequately particularised order was remitted for fresh consideration under Section 73, with possible recourse to Section 74 if information remained unprovided.
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