Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
Rectification of patent errors in GST proceedings is confined to errors apparent on the face of the record and cannot be used to revisit an original determination on under-declared ineligible input tax credit. Where no apparent error is established and supporting documents were not submitted, rejection of a rectification application remains undisturbed. The taxpayer may challenge the original determination independently in accordance with law, rather than seek substantive reconsideration through rectification.
Rectification of patent errors in GST proceedings is confined to errors apparent on the face of the record and cannot be used to revisit an original determination on under-declared ineligible input tax credit. Where no apparent error is established and supporting documents were not submitted, rejection of a rectification application remains undisturbed. The taxpayer may challenge the original determination independently in accordance with law, rather than seek substantive reconsideration through rectification.
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