Origin Declaration authentication governs preferential tariff claims under India-UK CETA, requiring a validated reference number before import clearan...
Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Extended limitation under Section 74 of the CGST Act for fraud, wilful misstatement or suppression of facts requires the show-cause notice itself to disclose specific allegations and the factual basis supporting that inference. A bare reference to "fraud or concealment of facts" does not establish a valid basis for invoking the extended period, and deficiencies in the notice cannot be cured through a counter affidavit. Where the ordinary limitation period has expired, including applicable exclusion of time, an unsupported invocation of extended limitation renders the notice unsustainable. Further proceedings based on such a notice cannot continue.
Extended limitation under Section 74 of the CGST Act for fraud, wilful misstatement or suppression of facts requires the show-cause notice itself to disclose specific allegations and the factual basis supporting that inference. A bare reference to "fraud or concealment of facts" does not establish a valid basis for invoking the extended period, and deficiencies in the notice cannot be cured through a counter affidavit. Where the ordinary limitation period has expired, including applicable exclusion of time, an unsupported invocation of extended limitation renders the notice unsustainable. Further proceedings based on such a notice cannot continue.
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