Effective hearing in GST adjudication requires actual opportunity to respond; ineffective service through a former auditor invalidated ex parte procee...
Third-party search material requires special assessment route, rendering general reassessment notices without jurisdiction when it forms the proceedin...
Transfer-pricing adjustments must be confined to international associated-enterprise transactions, while functionally dissimilar comparables remain ex...
Insolvency moratorium bars income-tax revision proceedings against corporate debtors until the moratorium ends, preserving merits for later determinat...
Input tax credit denial based solely on a GSTR-2A/GSTR-3B mismatch requires transaction-level verification of reconciliations, invoices, records and supplier-tax-payment conditions; a mismatch alone does not establish ineligibility. Section 16(2)(aa) does not apply to the disputed period, while Rule 36(4) must be applied as operative during each relevant portion. Tax demands must remain within the grounds and tax heads proposed in the show-cause notice, supported by a reasoned computation and factual basis. The CBIC ITC-verification mechanism applies only from April 2019 to 8 October 2019, requiring separate examination of later periods under the applicable substantive provisions.
Input tax credit denial based solely on a GSTR-2A/GSTR-3B mismatch requires transaction-level verification of reconciliations, invoices, records and supplier-tax-payment conditions; a mismatch alone does not establish ineligibility. Section 16(2)(aa) does not apply to the disputed period, while Rule 36(4) must be applied as operative during each relevant portion. Tax demands must remain within the grounds and tax heads proposed in the show-cause notice, supported by a reasoned computation and factual basis. The CBIC ITC-verification mechanism applies only from April 2019 to 8 October 2019, requiring separate examination of later periods under the applicable substantive provisions.
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