Year-wise GST tax periods make composite show cause notices impermissible, requiring separate proceedings despite contrary non-jurisdictional preceden...
Reassessment notices alleging fictitious or accommodation transactions must disclose material particulars and incriminating material that prima facie link the assessee to the alleged transactions. Screenshots of Case Related Information Detail, without the underlying dissemination reports or transaction details, do not provide a meaningful statutory opportunity to respond. The Assessing Officer must independently consider the dissemination material and address objections and supporting evidence. Supplying foundational material only during writ proceedings cannot cure the defect. Failure to meet these requirements resulted in quashing of the reassessment notice, the consequential order, and the subsequent notice, without remand.
Reassessment notices alleging fictitious or accommodation transactions must disclose material particulars and incriminating material that prima facie link the assessee to the alleged transactions. Screenshots of Case Related Information Detail, without the underlying dissemination reports or transaction details, do not provide a meaningful statutory opportunity to respond. The Assessing Officer must independently consider the dissemination material and address objections and supporting evidence. Supplying foundational material only during writ proceedings cannot cure the defect. Failure to meet these requirements resulted in quashing of the reassessment notice, the consequential order, and the subsequent notice, without remand.
Note: It is a system-generated summary and is for quick reference only.
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TaxTMI 
