Retrospective invalidity of ocean-freight IGST supports refunds despite non-party status and prior credit utilisation, subject to authorised appeal gr...
Additional evidence in departmental appeals may include show-cause-notice material without introducing a new case where it merely corroborates existin...
Reasoned rectification orders require consideration of expenditure disclosed in income-tax returns, preventing revision based on incomplete income com...
Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer...
Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or o...
TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
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Availability of a statutory appellate remedy against GST registration cancellation and rejection of revocation ordinarily precludes adjudication of factual disputes in writ jurisdiction. Appeals lay against both orders; therefore, factual contentions remained open for determination by the appellate authority. Where the revocation-rejection order was undated but served on 22 August 2026, the service date was directed to be treated as the order date for pursuing the appellate remedy. The taxpayer was permitted to file appeals against both orders within two weeks, for expeditious disposal.
Availability of a statutory appellate remedy against GST registration cancellation and rejection of revocation ordinarily precludes adjudication of factual disputes in writ jurisdiction. Appeals lay against both orders; therefore, factual contentions remained open for determination by the appellate authority. Where the revocation-rejection order was undated but served on 22 August 2026, the service date was directed to be treated as the order date for pursuing the appellate remedy. The taxpayer was permitted to file appeals against both orders within two weeks, for expeditious disposal.
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