Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Customs valuation and classification require comparable evidence and assessment of imported goods in their actual condition, invalidating related pena...
Notification extending the annual return due date for 2017-18 did not extend the department's time to initiate Section 74 fraud proceedings; no separate extension notification for Section 74 was shown, and the March 2021 communication was only a scrutiny notice, not a valid show cause notice. For 2018-19 and 2019-20, parallel CGST proceedings on excess availment of input tax credit were barred where SGST had already initiated action on the same subject matter, making that part of the notice without jurisdiction. The short-payment component, however, was distinct from the SGST mismatch proceedings and could be pursued. The composite order was set aside and remitted for fresh adjudication only on the issues lawfully open to the authority.
Notification extending the annual return due date for 2017-18 did not extend the department's time to initiate Section 74 fraud proceedings; no separate extension notification for Section 74 was shown, and the March 2021 communication was only a scrutiny notice, not a valid show cause notice. For 2018-19 and 2019-20, parallel CGST proceedings on excess availment of input tax credit were barred where SGST had already initiated action on the same subject matter, making that part of the notice without jurisdiction. The short-payment component, however, was distinct from the SGST mismatch proceedings and could be pursued. The composite order was set aside and remitted for fresh adjudication only on the issues lawfully open to the authority.
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