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...
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Reassessment notices for AY 2015-16 issued on or after 1 April 2021 were required to be dropped because the extended period did not preserve the power to issue fresh notices after limitation expired. Reassessment is also without jurisdiction where a return filed in response to a reassessment notice before completion is treated as non-existent solely because it was belated and no notice under section 143(2) is issued. For reopening beyond three years, prior approval from the higher specified authority is mandatory; TOLA's time extension does not alter the statutory hierarchy, making approval by the Principal Commissioner insufficient.
Reassessment notices for AY 2015-16 issued on or after 1 April 2021 were required to be dropped because the extended period did not preserve the power to issue fresh notices after limitation expired. Reassessment is also without jurisdiction where a return filed in response to a reassessment notice before completion is treated as non-existent solely because it was belated and no notice under section 143(2) is issued. For reopening beyond three years, prior approval from the higher specified authority is mandatory; TOLA's time extension does not alter the statutory hierarchy, making approval by the Principal Commissioner insufficient.
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