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...
GST adjudication challenges involving the extended-demand provision, audit objections, input tax credit, reverse-charge liability, export transactions and factual demand heads require statutory appellate review where the taxpayer participated in proceedings and had an opportunity to present its defence. A disagreement over the evaluation of replies, documents or evidence differs from a denial of natural justice and does not by itself justify writ jurisdiction. A consolidated show cause notice may cover multiple financial years because the statutory language permits notices for periods, while limitation for the order is calculated by financial year. Limitation for an individual year remains available for determination in appeal. Writ interference is unavailable absent patent lack of jurisdiction or manifest breach of natural justice.
GST adjudication challenges involving the extended-demand provision, audit objections, input tax credit, reverse-charge liability, export transactions and factual demand heads require statutory appellate review where the taxpayer participated in proceedings and had an opportunity to present its defence. A disagreement over the evaluation of replies, documents or evidence differs from a denial of natural justice and does not by itself justify writ jurisdiction. A consolidated show cause notice may cover multiple financial years because the statutory language permits notices for periods, while limitation for the order is calculated by financial year. Limitation for an individual year remains available for determination in appeal. Writ interference is unavailable absent patent lack of jurisdiction or manifest breach of natural justice.
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