Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
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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