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...
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Retrospective extension of the input tax credit limitation under section 16(5) protects eligible registered persons whose belated claims were barred under section 16(4) but fall within the extended period. Input tax credit cannot be denied solely on limitation in such circumstances. The assessment disallowance was quashed to that extent, consequential recovery was restrained, and amounts already recovered were to be refunded or adjusted against future tax liabilities.
Retrospective extension of the input tax credit limitation under section 16(5) protects eligible registered persons whose belated claims were barred under section 16(4) but fall within the extended period. Input tax credit cannot be denied solely on limitation in such circumstances. The assessment disallowance was quashed to that extent, consequential recovery was restrained, and amounts already recovered were to be refunded or adjusted against future tax liabilities.
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