GST payment representations require record-based, reasoned decisions while substantive entitlement remains open for determination by competent authori...
Reassessment sanction under extended limitation required approval from the competent specified authority, invalidating proceedings approved by an inco...
Internal CUP benchmarking for fixed-rate Masala Bonds prevails over floating external comparables, eliminating the related transfer-pricing adjustment...
Jurisdictional validity of revision notices: incorrect official capacity and mere change of opinion invalidate revision of property income assessments...
Show-cause notices for alleged wrongful input tax credit under section 74 must state the specific reasons for the proposed tax action; merely reproducing the statutory provision is insufficient. Relevant documents requested for defence must also be supplied so that the noticee can participate effectively in the proceedings. A foundationally defective notice cannot be cured at appellate or revisional stages. On these principles, the defective notice, consequential recovery order and bank-account attachment were quashed, with liberty to issue a fresh reasoned notice and decide the matter afresh in accordance with law.
Show-cause notices for alleged wrongful input tax credit under section 74 must state the specific reasons for the proposed tax action; merely reproducing the statutory provision is insufficient. Relevant documents requested for defence must also be supplied so that the noticee can participate effectively in the proceedings. A foundationally defective notice cannot be cured at appellate or revisional stages. On these principles, the defective notice, consequential recovery order and bank-account attachment were quashed, with liberty to issue a fresh reasoned notice and decide the matter afresh in accordance with law.
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