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...
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Foundational facts supported invocation of the extended period under GST Section 74, because the notices set out detailed allegations of incorrect valuation, inadmissible credit-note adjustment and short payment of tax, backed by investigation material and prior intimation; the writ challenge was therefore rejected as the disputed factual issues were not fit for writ review. Prior audit and earlier investigation did not defeat jurisdiction, because audit under Section 65 is distinct from a pan-India DGGI investigation, and overlap alone did not invalidate notices where separate grounds of evasion were alleged. The proceedings were held maintainable and the taxpayer was directed to reply before the adjudicating authority.
Foundational facts supported invocation of the extended period under GST Section 74, because the notices set out detailed allegations of incorrect valuation, inadmissible credit-note adjustment and short payment of tax, backed by investigation material and prior intimation; the writ challenge was therefore rejected as the disputed factual issues were not fit for writ review. Prior audit and earlier investigation did not defeat jurisdiction, because audit under Section 65 is distinct from a pan-India DGGI investigation, and overlap alone did not invalidate notices where separate grounds of evasion were alleged. The proceedings were held maintainable and the taxpayer was directed to reply before the adjudicating authority.
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