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...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
Unconditional omission of Rule 96(10) of the CGST/WBGST Rules, 2017, without a saving clause, rendered the rule nonexistent for proceedings founded solely on it. Applying Supreme Court law on the effect of such omission, the High Court found that the impugned proceedings had no independent statutory basis. The show-cause notice and consequential orders concerning July 2017 to March 2021 were therefore quashed, and the writ petition was disposed of.
Unconditional omission of Rule 96(10) of the CGST/WBGST Rules, 2017, without a saving clause, rendered the rule nonexistent for proceedings founded solely on it. Applying Supreme Court law on the effect of such omission, the High Court found that the impugned proceedings had no independent statutory basis. The show-cause notice and consequential orders concerning July 2017 to March 2021 were therefore quashed, and the writ petition was disposed of.
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TaxTMI 
TaxTMI 
of 4894 
