Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Natural justice in insolvency-professional discipline requires disclosed material; notices based on extraneous material and ignored defences are vitia...
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Consolidated show-cause notices covering multiple financial years are maintainable under Sections 73 and 74 of the CGST and SGST enactments, which do not prohibit clubbing tax periods in one notice. Quashing such a notice and consequential orders solely because multiple years were combined is unsustainable. An appellate authority must also provide an effective hearing on the merits where the appellant seeks condonation of delay and admission of the appeal for that purpose. Restricting the hearing to delay and deciding the appeal without a merits hearing breaches principles of natural justice. The appellate order was set aside and remitted for a merits hearing.
Consolidated show-cause notices covering multiple financial years are maintainable under Sections 73 and 74 of the CGST and SGST enactments, which do not prohibit clubbing tax periods in one notice. Quashing such a notice and consequential orders solely because multiple years were combined is unsustainable. An appellate authority must also provide an effective hearing on the merits where the appellant seeks condonation of delay and admission of the appeal for that purpose. Restricting the hearing to delay and deciding the appeal without a merits hearing breaches principles of natural justice. The appellate order was set aside and remitted for a merits hearing.
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